- 3 - Part of the exhibits received into evidence is photocopies of four canceled checks, each in the amount of $2,000, all drafted on an account labeled, “The Law Offices of Michael J. Rovell, Chtd. - Office Account #1”, and all made payable to the Illinois Department of Revenue. The Court also received at trial two letters sent to petitioner by his attorney, Michael Moss (Mr. Moss), for legal services rendered between May 10 and December 31, 2001. At the conclusion of the trial, the Court ordered that the record in this case be held open so that petitioner could submit additional documents substantiating the other miscellaneous and business expense deductions listed on the Schedule A. In response to this order, petitioner submitted photocopies of three canceled checks in the amounts of $7,000, $4,000, and $1,600, all drafted on an account labeled, The Law Offices of Michael J. Rovell, Chtd. - Office Account #1, and all made payable to Michael Moss. These checks were dated 2/20/01, 6/26/01, and 7/13/01. These three checks were the only documents petitioner submitted to the Court before the record was closed on August 23, 2006. Discussion The determinations of the Commissioner in a notice of deficiency are presumed correct, and the burden is on the taxpayer to prove that the determinations are in error. RulePage: Previous 1 2 3 4 5 6 7 8 NextLast modified: November 10, 2007