Anthony J. Marzullo and Mary P. Marzullo - Page 5

                                         -5-                                          
          Bifurcated Salary                                                           
               The College of Notre Dame waived tuition for students whose            
          parents were college employees.  Petitioners could not take                 
          advantage of the tuition waiver benefit because they had sons and           
          the College admitted women only.                                            
               Mr. Marzullo wanted to receive a benefit that was similar to           
          the tuition waiver.  He also wanted to structure his compensation           
          package with the College to mitigate, at least to some degree, the          
          loss of benefits he had been receiving from his previous employer.          
          To achieve these results, Mr. Marzullo devised a bifurcated salary          
          arrangement for himself, in which only a portion of his income was          
          paid as salary and reported by the College to the Internal Revenue          
          Service (IRS) on a Form W-2.  The balance of his compensation was           
          transferred to an accounts payable account that normally was used           
          for nontaxable employee reimbursement.  That  part  of  his                 
          compensation (which was not reported to the IRS on a Form W-2) was          
          paid to Mr. Marzullo or to third parties for Mr. Marzullo's                 
          benefit.  Mr. Marzullo used the unreported money to pay for such            
          things as credit card bills for a family vacation, bills for his            
          life and disability insurance premiums, and his sons' tuition.  The         
          payments classified to the accounts payable account which were              
          omitted from petitioners' Federal income tax returns were:                  
                              Year      Amount                                        
                              1986      $12,322                                       
                              1987      29,296                                        
                              1988      21,542                                        




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