Michael J. Rovell - Page 4




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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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