Ronald B. and Annette C. Talmage - Page 34




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               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 the                      








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