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A. 1990
In 1990, Taxman paid $310 to Garry Pearson, an attorney whom
petitioner consulted regarding his 1982, 1983, and 1984 tax
returns. Also in 1990, Taxman made two payments totaling $2,147
to West Far-Mor Credit Union in satisfaction of a 1989 loan to
petitioner. Petitioner did not report either payment as income
on his 1990 tax return.
B. 1991
In January 1991, Taxman issued two checks to petitioner
totaling $2,052. Petitioner did not report the $2,052 as income
on his 1991 tax return.
Also in January 1991, petitioner bought several pieces of
furniture from Conlin’s Furniture (Conlin’s). The total price of
the furniture was $4,034.10. The cost of the furniture was
charged to petitioner’s Visa card in January and April 1991.
Taxman made all the payments on petitioner’s Visa during 1991 and
1992. For 1991 and 1992, Taxman paid $2,086 and $1,904,
respectively, toward the furniture purchase.4 Petitioner did not
include the amount paid for the furniture from Conlin’s as income
on his 1991 or 1992 personal income tax return.
4The notice of deficiency states that Taxman paid only
$1,904. However, the credit card statements reflect that Taxman
paid $1,948.10 toward the furniture purchase in 1992. For
simplicity’s sake, we refer to the 1992 amount as $1,904 as
stated in the notice of deficiency.
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