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Kory Talmage, and Lillian Talmage resided together in Japan
throughout 1999. Petitioner did report taxable interest of
$3,428 and claimed personal exemptions for himself and Kumiko
Talmage and dependency exemptions for Kory Talmage and Lillian
Talmage resulting in petitioner’s calculation of “0” taxable
income. The 1999 return did not claim a deduction for interest
paid.
On June 1, 2000, Kumiko Talmage filed for divorce.
Petitioner’s immediate reaction was to prepare, or have prepared
and signed, three documents, all dated June 16, 2000; i.e., an
addendum to his employment agreement dated December 31, 1998, a
loan reconfirmation agreement, and a letter written by Mr. Seki
to petitioner and Kumiko Talmage which set out the total amount
purportedly lent to date.
The addendum to the December 23, 1998, employment contract,
dated June 16, 2000, stated:
[Petitioner] is employed by NCPL in accordance with the
terms of the Employment Contract executed the 23rd day
of December 1998,
and
RBT is currently undergoing a marital dispute,
-- The undersigned agree to the following adjustment to
RBT’s remuneration/compensation package:
(1) [Petitioner’s] monthly salary [is] temporarily
increased to US$9,000 per month during the period of
“Temporary Family Support” as dictated by the pending
divorce filing by his spouse, Kumiko W. Talmage (filing
dated June 1, 2000, with Multnomah County, State of
Oregon, USA).
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Last modified: March 27, 2008