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Thompson and issued by Polaris. Nor did Ms. Thompson report in
Ms. Thompson’s 1995 return or in Ms. Thompson’s 1996 return rents
received from “An undivided 1/2% interest in four used aircraft
Pittsburg [sic], PA” or any other amount attributable to Mr.
Thompson’s investment.15 On the record before us, we find that
petitioner has failed to carry his burden of showing that he does
not have: (1) Unreported income of $4,962.50 and $4,962.50,
respectively, for 1995 from his use of the January 31, 1995 check
and the July 31, 1995 check, which were payable to Mr. Thompson
and issued by Polaris with respect to Mr. Thompson’s investment;
15Pursuant to Rule 90(c), the following matters are deemed
admitted:
4. On October 16, 2001, petitioner, alleging to
respondent that his mother was the actual recipient of
certain income items that were attributable to peti-
tioner in the statutory notice of deficiency, told
respondent in the presence of his mother that his
mother would amend her federal income tax returns for
1995 and 1996 to report the income.
5. Although respondent stated that he expected
any amended returns to be sent to him and to be filed
within thirty days of the meeting and although respon-
dent informally extended the deadline for filing the
amended tax returns, the last time to March 5, 2002, no
amended returns have been filed by petitioner or his
mother.
As of the trial in this case, petitioner had not proffered any
amended return of Ms. Thompson for 1995 reflecting that she
reported for that year the January 31, 1995 check and the July
31, 1995 check payable to Mr. Thompson and issued by Polaris or
any amended return for 1996 reflecting that she reported the
January 31, 1996 check and the July 31, 1996 check payable to Mr.
Thompson and issued by Polaris.
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