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During 1999, Caspian made the following disbursements to
petitioner:
9/16/1999 $578,034.59
10/7/1999 65,000.00
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Total Disbursements
For 1999: $643,034.59
These disbursements were identified on Caspian’s books as
“Employee Advances”. At the end of 1999, the advances were
converted to “notes” on Caspian’s books. Petitioner used these
funds in connection with the purchase of a new home.
Petitioner and Ms. Ferrando-Teymourian jointly filed a
Federal individual income tax return for 1999, reporting $233,097
of adjusted gross income and $136,519 of taxable income.5 They
did not report the disbursements received from Caspian as income,
nor did they report rental income.
During 2000, Caspian made the following disbursements to or
on behalf of petitioner:
1/05/2000 Bill $108.40
1/12/2000 Check 120,000.00
1/17/2000 Credit Card Charges 7,258.21
2/29/2000 Transfer 80,000.00
3/17/2000 Credit Card Charges 2,200.00
3/28/2000 Transfer 40,000.00
4/16/2000 Credit Card Charges 98.52
4/17/2000 Bills 52,000.00
5 Ms. Ferrando-Teymourian has a separate suit pending in
this Court, docket No. 18139-03, and is not a party to the
present case.
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