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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. Rule
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