Howard H. Thompson, Jr. - Page 39

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          addition, Mr. Caylor’s affidavit indicated that petitioner used             
          Weavewood’s funds to pay for the lease of petitioner’s personal             
          automobile lease.  On the record before us, we find that peti-              
          tioner has failed to carry his burden of showing that he used for           
          or on behalf of Weavewood the June 13, 1996 check that was                  
          payable to Gold Key and drawn on Weavewood’s checking account.              
          On that record, we further find that petitioner has failed to               
          carry his burden of showing that he does not have unreported                
          income of $549.99 for 1996 from his use of that check.                      
               July 16, 1996 Checks and July 22, 1996                                 
               Checks That Were Payable to Weavewood                                  
               With respect to petitioner’s use of the July 16, 1996 checks           
          and the July 22, 1996 checks that were payable to Weavewood, the            
          record establishes that petitioner deposited those checks into              
          petitioner’s checking account without Weavewood’s authorization             
          and that such deposits constituted a conversion of those checks.            
          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 $10,720.31 and $8,288.23, respec-             
          tively, for 1996 from his use of the July 16, 1996 checks and the           
          July 22, 1996 checks that were payable to Weavewood.                        
               February 14, 1996 Check                                                
               With respect to the February 14, 1996 check relating to                





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