- 41 - him in 1991 because it was a reimbursement of the earlier expense he paid on behalf of Taxman. The statement of income tax examination changes from the 1987 audit disallows a $2,052 deduction from petitioner’s Schedule C. This statement is signed by the revenue agent with a date of December 28, 1990. The record also includes a portion of a letter from the IRS to petitioner and Lori explaining that the $2,052 was removed because it was “not an expense of the * * * [taxpayer], but an expense of another”. The only references to a “reimbursement” on the audit documents are handwritten notes by petitioner. No official correspondence from the revenue agent refers to reimbursement. Petitioner has shown that an expense of $2,052 was disallowed on his 1987 personal return. However, he has not shown that he actually paid the expense on Taxman’s behalf in 1987, that it was a properly deductible expense of Taxman, or that the revenue agent instructed him that reimbursement was an appropriate course of action. We do not believe that petitioner has met his burden of proving that the $2,052 Taxman paid him in 1991 was reimbursement for an expense petitioner paid in 1987. Therefore, the $2,052 is income to petitioner in 1991. During 1991, petitioner bought furniture using a credit card issued in his name. All of the payments on the credit card during 1991 and 1992 were made by Taxman. In 1991, Taxman paidPage: Previous 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 Next
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