- 19 -
Petitioners never reported any of CAI's funds used by them
as income on a personal tax return. The total amount of CAI
funds in the A, C, and set-off accounts used for petitioners'
benefit totaled $705,107.17 Of this amount, $245,008 was used in
1980, $312,269 was used in 1981, and $147,830 was used in 1982.
Petitioner was aware that he could be charged with income from
CAI and the resulting tax liability.
6. Reporting Requirements
Petitioners' 1980 through 1982 tax returns were prepared by
their accountant, Seymour Schiller (Mr. Schiller). In connection
with the preparation of those returns, petitioner did not tell
Mr. Schiller that petitioners had an interest in a foreign
account during the relevant years. Petitioners indicated on
their 1980 and 1981 tax returns that they did not have such an
interest during 1980 and 1981. Petitioners did not report on
their 1982 tax return that they had an interest in a foreign
account during 1982. Petitioners had an interest in CAI's bank
account during each of the subject years.
7. Mrs. Fields
Mrs. Fields is an educated woman, and she has been involved
in the business world in a limited capacity. She received a
17 Respondent seeks to include only $669,124 of this income
in petitioners' gross income.
Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NextLast modified: May 25, 2011