Gabino Diaz - Page 3

          additional checks.  Again, the signatures on the checks are                 
               Respondent, concluding that the above documentation was                
          inadequate, disallowed all $36,182 of the deductions claimed on             
          Schedule A, Itemized Deductions, of petitioner’s 2003 Federal               
          income tax return ($23,885 in home mortgage interest, $8,673 in             
          state income tax, $363 in contributions, and $3,261 in                      
          miscellaneous expenses).                                                    
               Petitioner protested respondent’s audit adjustments to                 
          respondent’s Appeals Office but did not explain to respondent’s             
          Appeals Office the confusing checks and signatures that                     
          petitioner had provided to respondent.                                      
               On November 28, 2005, respondent determined a deficiency of            
          $6,077 in petitioner’s 2003 Federal income taxes.  The deficiency           
          was based on a disallowance by respondent of the $36,182 claimed            
          Schedule A deductions.                                                      
               On January 25, 2006, petitioner filed a petition regarding             
          respondent’s November 28, 2005, notice of deficiency.  In the               
          petition, petitioner claimed that the documentation petitioner              
          submitted to respondent during the audit adequately substantiated           
          the deductions respondent had disallowed.                                   
               On March 7, 2006, respondent filed an answer in which                  
          respondent argued that the documentation petitioner submitted to            

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