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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 paid
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