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all Rule references are to the Tax Court Rules of Practice and
Procedure.
Background
At the time the petition was filed, petitioner resided in
Newhall, California.
On approximately February 10, 2004, petitioner timely filed
his 2003 Federal income tax return.
During respondent’s audit of petitioner’s 2003 Federal
income tax return, petitioner submitted to respondent certain
documentation. The documents included various checks and
mortgage interest statements to petitioner and to one other
individual. Printed on the checks as owners of the bank account
on which the checks are drawn are the names of petitioner and two
other individuals. The checks are made payable to various
companies and individuals. The signatures on most of the checks
are illegible. None of the checks appears to be signed by
petitioner. The record does not indicate the relationship
between petitioner and the other individuals whose names appear
on the checks and on the interest statements.
Also during respondent’s audit, petitioner submitted
additional documentation which included an automobile lease
agreement in petitioner’s name, Form W-2, Wage and Tax Statement,
relating to wages paid to petitioner, and copies of three
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Last modified: November 10, 2007