- 34 - On April 10, 2003, petitioners filed their 2002 joint return and reported a salary from an “Overseas Employer” of $75,000 and a Schedule F loss of $22,875, with a tax liability of $2,501. Petitioner’s Schedule A for 2002 reported a real estate tax deduction of $9,545. The 2002 return did not claim a deduction for interest paid. B. Respondent’s Examination In late 2003, the Japanese taxing authorities, as part of an information exchange, informed respondent that petitioner, a U.S. citizen, and TPPL were involved in a business transaction in which TPPL received over $5 million in 2000. The Japanese taxing authorities also disclosed documents which stated that petitioner was the CEO and chairman of TPPL and that he resided at the Rivercliff property. While investigating petitioner, Revenue Agents Steve Rans and Christopher Beach discovered the Rivercliff property was titled in the Talmages’ names and that SSI was involved in a large construction project on the property. On January 22, 2004, Agent Rans mailed a letter to petitioner asking whether he held an ownership interest in TPPL or NCPL. The letter referred to documents in which petitioner identified himself as the chairman, the chairman and CEO, and the managing partner and chairman of TPPL. The letter also requested that petitioner disclose the source of funding for thePage: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 NextLast modified: March 27, 2008