- 40 - 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.Page: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
Last modified: May 25, 2011