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Weavewood, all of which respondent included as part of the
adjustment in the notice, referred to as “EMBEZZELMENT [sic] FORM
1099", to increase petitioner’s income for 1996 by $122,391:11
(1) Petitioner’s use of Weavewood’s February 1996 checks that
were payable to Ms. Thompson and drawn on Weavewood’s checking
account; (2) petitioner’s use of Weavewood’s February and April
1996 checks that were payable to Mr. Cavness or Mr. Villaume and
drawn on Weavewood’s checking account; (3) petitioner’s use of
Weavewood’s July 12, 1996 checks that were payable to petitioner
and drawn on Weavewood’s checking account; (4) petitioner’s use
of Weavewood’s March and April 1996 checks that were payable to
Mr. Robinson and drawn on Weavewood’s checking account;
(5) petitioner’s use of Weavewood’s May and June 1996 checks that
were payable to Gold Key and drawn on Weavewood’s checking
account; (6) petitioner’s use of the July 16, 1996 checks and the
July 22, 1996 checks that were payable to Weavewood; and
(7) petitioner’s receipt of the February 14, 1996 check relating
11The amount of $122,391 by which respondent determined in
the notice to increase petitioner’s income for 1996 was the
amount reported in Form 1099-MISC, Miscellaneous Income (Form
1099), that Weavewood issued for that year with respect to
petitioner (Weavewood’s Form 1099). In preparation for trial,
respondent reconstructed various items of unreported income for
1996, which were included as part of the $122,391 total amount of
income reported in Weavewood’s Form 1099. Except for the unre-
ported income items for 1996 that we address herein, respondent
concedes the balance of the $122,391 of unreported income for
1996 that respondent determined in the notice as an adjustment
referred to in the notice as “EMBEZZELMENT [sic] FORM 1099”.
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