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petitioner’s spousal and child support obligations. Petitioner
did not report any of the transferred funds as income on his Form
1040 for 2001 (2001 return).
On April 11, 2001, petitioner filed his 2000 return with a
filing status of head of household, claiming an exemption for his
daughter, Lillian Talmage. The 2000 return reported a salary
from an “Overseas Employer” of $84,000, interest income of
$1,406, a loss of $31,239 on Schedule F, Profit and Loss from
Farming, and a child tax credit of $500, with a tax liability of
$6,460.9 Petitioner did not report the portion of his salary used
to pay his spousal and child support obligations. The 2000
return also did not claim a deduction for interest paid and did
not indicate petitioner’s employer was NCPL.
On May 30, 2001, Steven W. Seymour (Mr. Seymour), an
attorney hired by B. Manek & Co., a Hong Kong firm of solicitors
(solicitors) representing NCPL and/or Mr. Seki, mailed a letter
to both Diane E. Rulien (Kumiko Talmage’s attorney) and Mr.
Larson, stating that NCPL had hired him to perfect a security
interest for NCPL in the Rivercliff property. The letter also
stated that petitioner and Kumiko Talmage were required to:
execute a mortgage in favor of my client [NCPL or Mr.
Seki] for recording in the real property records of
Multnomah County, Oregon. In the event that either, or
9 NCPL transferred $3,980 of petitioner’s $9,000 monthly
salary to Kumiko Talmage on Aug. 8, Sept. 11, Oct. 10, Nov. 10,
and Dec. 15, 2000.
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Last modified: March 27, 2008