Nariman Teymourian - Page 7

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               Petitioner and Ms. Ferrando-Teymourian jointly filed a                 
          Federal individual income tax return for 2000, reporting $797,682           
          of adjusted gross income and $637,805 of taxable income.  They              
          did not report the disbursements made by Caspian as income, nor             
          did they report rental income.                                              
               During the years in issue, Caspian made no formal                      
          declaration or payment of a dividend.  Petitioner and Caspian did           
          not execute formal loan instruments with respect to the amounts             
          disbursed to or paid on behalf of petitioner.                               
               In the fall of 2001, respondent’s examining agent, Roseann             
          Kacheris (Ms. Kacheris), began investigating Caspian’s corporate            
          tax returns for 1999 and 2000.  During the course of her                    
          investigation, she also examined petitioner’s individual income             
          tax returns for the years in issue.                                         
               On July 24, 2003, respondent issued petitioner a notice of             
          deficiency for 1999 and 2000.  In the notice, respondent made the           
          following increases to petitioner’s taxable income:                         
               1999                                                                   
               Type of Adjustment       Amount of Increase                            
               Capital gain                  $137,880                                 
               Itemized deductions           24,149                                   
               Exemptions                    5,155                                    
               Rental income                 19,800                                   
               Dividends                     647,290                                  
               ____________________________________________                           
               Total Adjustments for 1999: $834,274                                   









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