- 35 -
February 1996 checks that were payable to Ms. Thompson and drawn
on Weavewood’s checking account.13
Weavewood’s February and April 1996 Checks
With respect to 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, the record
establishes that petitioner used those checks to make payments
for petitioner’s personal expenses or to make payments to a
nominee of petitioner. On the record before us, we find that
petitioner has failed to carry his burden of showing that he used
those checks for or on behalf of Weavewood. On that record, we
further find that petitioner has failed to carry his burden of
showing that he does not have unreported income of $8,350 for
1996 from his 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.
Weavewood’s July 12, 1996 Checks
With respect to petitioner’s use of Weavewood’s July 12,
1996 checks that were payable to petitioner and drawn on
13As discussed above, in Ms. Thompson’s supplemental affida-
vit which she wrote in July 1996 in connection with Weavewood’s
memorandum of law filed on July 22, 1996, Ms. Thompson denied
having received any moneys from Weavewood since August 1995.
Moreover, Ms. Thompson did not report as income in Ms. Thompson’s
1996 return Weavewood’s February 1996 checks totaling $26,000
that were payable to her, that petitioner signed, and that were
drawn on Weavewood’s checking account.
Page: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 NextLast modified: May 25, 2011