Bradley M. Cohen and Kathy A. Cohen - Page 5




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          account.  Of these deposits, $3,500 were nontaxable transfers               
          from bank accounts controlled by petitioners.  Petitioners also             
          deposited $141,130.52 into the Cohen account during 1996.  Of               
          these deposits, $74,857 represented nontaxable items.                       
          Petitioners had unexplained deposits into the two accounts in               
          1996 totaling $78,791.02.                                                   
               During 1996, petitioners maintained a brokerage account with           
          Bear, Sterns & Co., Inc. (brokerage account).  Petitioners                  
          recognized short- and long-term capital gains of $18,521 in 1996.           
          Federal Tax Returns                                                         
               Grey acted as petitioners’ accountant and filed both                   
          business and personal returns for petitioners beginning in or               
          around 1983.  Petitioners filed a joint Federal income tax return           
          for 1996 on July 18, 1997.  They reported adjusted gross income             
          of $10,075.42, no taxable income, and self-employment tax of                
          $1,067.77.  On their Schedule C, petitioners reported gross                 
          receipts of $20,680, other income of $80, and expenses of                   
          $13,202.96. Petitioners reported a net profit of $7,557.04 as               
          business income on their return.  Grey prepared petitioners’                
          personal return and the Form 1120 for NHIL.  Grey reviewed the              
          return with petitioners, who then signed the return.                        
               On July 8, 1998, petitioners filed a Form 1040X, Amended               
          U.S. Individual Income Tax Return, for 1996.  The only change               
          reported on this return was a claim by petitioners for the earned           






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