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Butte property were deposited in the Talmages’ account at US
Bank. The record does not reflect where the proceeds from the
sale of the Vancouver property were deposited. The proceeds from
the sales of the properties were used for the Talmages’ personal
expenses and to develop the Rivercliff property.
Petitioner did not report receiving any income from the sale
of the Vancouver or the Black Butte property on his 1998 return.
Petitioner also did not report receiving rental income or claim
deductions for depreciation, mortgage interest, or property tax
with respect to the Vancouver property on his 1998 return.
On November 3, 1998, petitioner paid $5,785 in property
taxes for the Rivercliff property.
On December 8, 1998, SSI’s bookkeeper sent a memorandum by
facsimile to petitioner stating:
The following invoice is the remainder due for
November.
Also, there is an “Invoice Summary” recapping all
invoice’s due with the billing address of your company.
Is this what you were looking for in the way of billing
to your company?
If you could confirm that the company, TPP Limited
[TPPL], is solely owned by you we would appreciate it.
On December 23, 1998, TPPL wire transferred $249,193 to SSI for
the remainder due on the development of the Rivercliff property
in 1998. Petitioner did not report the $249,193 as income on his
1998 return.
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Last modified: March 27, 2008