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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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