Howard H. Thompson, Jr. - Page 40

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          Timmerman Leasing, the record establishes that petitioner re-               
          ceived that check.  On the record before us, we find that peti-             
          tioner has failed to carry his burden of showing that he used               
          that check 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 $6,000 for               
          1996 from his receipt of the February 14, 1996 check relating to            
          Timmerman Leasing.                                                          
          Transactions Involving Petitioner and                                       
          Checks That Were Payable to Mr. Thompson                                    
               With respect to petitioner’s use (1) in 1995 of the January            
          31, 1995 check and the July 31, 1995 check and (2) in 1996 of the           
          January 31, 1996 check and the July 31, 1996 check, all of which            
          were payable to Mr. Thompson, petitioner’s father, and issued by            
          Polaris with respect to Mr. Thompson’s investment, petitioner               
          claims on brief that he cashed those checks for, and that he gave           
          the proceeds from those checks to, his mother Ms. Thompson.  Ms.            
          Thompson’s 1995 return and Ms. Thompson’s 1996 return belie that            
          claim.  In Ms. Thompson’s 1995 return and Ms. Thompson’s 1996               
          return, Ms. Thompson reported taxable interest income from                  
          “POLARIS” of $178 and $171, respectively.  Ms. Thompson did not             
          report (1) in Ms. Thompson’s 1995 return the January 31, 1995               
          check and the July 31, 1995 check payable to Mr. Thompson and               
          issued by Polaris or (2) in Ms. Thompson’s 1996 return the                  
          January 31, 1996 check and the July 31, 1996 check payable to Mr.           





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