Howard H. Thompson, Jr. - Page 36

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          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.             





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