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underpayments of tax required to be shown on the
petitioner's income tax returns for the taxable years
1991, 1992 and 1993 is due to fraud, the respondent
alleges:
a. The petitioner has not filed a return for the
1991 taxable year.
b. The petitioner filed his 1992 and 1993 returns
on September 17, 1993 and October 14, 1994,
respectively.
c. During the 1991, 1992 and 1993 taxable years,
petitioner was the sole proprietor of a bar in New
Haven, Connecticut known as "Newt's Cafe".
* * * * * * *
f. For the 1991 taxable year, the respondent
determined that the petitioner * * * [had gross
receipts] totalling $365,464.00 in the aggregate.
* * *
g. For the 1992 taxable year, the respondent
determined that the petitioner * * * [had gross
receipts] totalling $359,427.00 in the aggregate.
* * *
h. For the 1993 taxable year, the respondent
determined that the petitioner * * * [had gross
receipts] totalling $294,026.00 in the aggregate.
* * *
i. Since the petitioner did not file a return for
1991, he did not report any gross receipts for Newt's
Cafe for 1991. For the 1992 and 1993 taxable years,
the petitioner reported gross receipts in the amounts
of $91,396.03 and $136,549.75, respectively, for Newt's
Cafe. Thus, the petitioner understated his gross
receipts from Newt's Cafe by $365,464.00, $268,031.00
and $157,476.00, for the 1991, 1992 and 1993 taxable
years, respectively.
* * * * * * *
l. During the 1992 and 1993 taxable years, the
petitioner received pension and IRA distributions in
the amounts of $10,924.00 and $14,500.00, respectively,
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