- 36 - Weavewood’s checking account, the record establishes that peti- tioner signed and negotiated those checks without Weavewood’s authorization. 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 $22,75014 for 1996 from his use of Weavewood’s July 12, 1996 checks that were payable to petitioner and drawn on Weavewood’s checking account. Weavewood’s March and April 1996 Checks With respect to petitioner’s use of Weavewood’s March and April 1996 checks that were payable to Mr. Robinson and drawn on Weavewood’s checking account, the record establishes that peti- tioner used those checks to make petitioner’s 1996 American Express card payments, which were for personal expenses of petitioner. On the record before us, we find that petitioner has failed to carry his burden of showing that any of the charges that petitioner made on petitioner’s American Express card issued on Mr. Robinson’s American Express account were incurred for or 14In determining that petitioner has unreported income of $22,750 as a result of petitioner’s use of Weavewood’s July 12, 1996 checks, respondent added the amounts of Weavewood’s July 12, 1996 checks for $16,000 and $16,750, respectively, and reduced that sum ($32,750) by $10,000 to take account of the fact that Norwest Bank-Ridgedale voided the $10,000 cashier’s check that petitioner received (along with $6,750 in cash) on July 16, 1996, when he negotiated Weavewood’s July 12, 1996 check for $16,750.Page: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
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