James O. Jondahl - Page 7

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          deposition, the clients who had sued petitioner agreed to accept            
          $3,000 each in satisfaction of petitioner’s obligations to them.            
          The two $3,000 payments were made by Taxman in 1990.  Petitioner            
          did not include the $6,000 paid by Taxman as income to him on his           
          1990 Federal income tax return.                                             
               Each of Taxman’s corporate returns for its taxable years               
          ending September 30, 1990, 1991, 1992, and 1993, was completed by           
          petitioner.  Mr. Jondahl is listed as the majority stockholder on           
          each return.  Petitioner determined Taxman’s income for its                 
          corporate returns from Taxman’s bank deposits.  During each year            
          at issue, approximately $3,000 of Taxman’s cash receipts was not            
          deposited in Taxman’s bank accounts.  Petitioner took possession            
          of the cash but did not keep records of how it was spent.  Some             
          of the cash was used by petitioner to pay personal expenses.                
          Petitioner did not report the cash amounts on his individual tax            
          returns.  Most of Taxman’s expenses, even amounts less than $2,             
          were paid by check.  During the 4 years in issue, Taxman issued             
          over 500 checks to various eating establishments, to Sam’s                  
          Wholesale Club, and for office supplies, snacks, and postage.               
               In September 1992, after petitioner was notified that the              
          IRS was auditing Taxman’s 1990 return, he typed up minutes of               
          annual directors meetings that he claims took place on October 5,           
          1987, October 2, 1989, and October 8, 1990. Petitioner claims               
          that he took handwritten notes of these meetings.  The minutes              






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