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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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