James G. LeBloch and Cathy Michelsen LeBloch - Page 17




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          same time, petitioners also filed an amended 1999 Federal income            
          tax return claiming without further explanation that $13,038                
          reported as compensation received from NT during 1999 was really            
          a loan repayment.  Each of these amended returns claimed a refund           
          resulting from the claimed recharacterization of the originally             
          reported compensation as loan repayments.  Respondent did not               
          grant either of those claims for refund.                                    
          F.  Petitioners’ Financial Accounts                                         
               1.  Overview                                                           
               Throughout the subject years, petitioners had 13 bank or               
          investment accounts (collectively, financial accounts).  Nine of            
          the financial accounts were in the name of LeBloch.  The                    
          remaining four financial accounts were in the name of Michelsen.            
               2.  LeBloch’s Accounts                                                 
               LeBloch had three financial accounts at the LAIRE Federal              
          Credit Union (LAIRE).  The first account, a primary savings                 
          account (LAIRE 00), was open from January 1, 1997, through                  
          February 12, 1999.  The second account, a checking account (LAIRE           
          50), was open during all of 1997 and 1998.  The third account, a            
          secondary savings account (LAIRE 01), was open from June 19                 
          through December 31, 1998.                                                  
               LeBloch had three financial accounts at the Postal & Federal           
          Employees Credit Union (PFE).  Each of these accounts was open              
          from September 24, 1998, through December 31, 1999.  These                  







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