Gabino Diaz - Page 7

          Most of the signatures on the checks were illegible.  The                   
          signatures that were legible were not those of petitioner.  Prior           
          to litigation it certainly is understandable that it was unclear            
          to respondent who actually paid the expenses in question.                   
               Further, in his answer, respondent acted reasonably in                 
          contesting the claimed deductions.  At the time respondent filed            
          his answer respondent neither knew nor should have known that               
          respondent’s position was incorrect.                                        
               Petitioner’s claim for reimbursement of litigation costs               
          will be denied.                                                             
               To reflect the foregoing,                                              
                                                  An appropriate order and           
                                             decision will be entered for             

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Last modified: November 10, 2007