James E. Jenkins and Ruth A. Jenkins - Page 2

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          petitioners’ 1994, 1995, 1996, and 1997 Federal income taxes.               
          The issues for decision are whether petitioners received                    
          unreported income and are liable for the section 6663(a)1 fraud             
          penalty.                                                                    
                                 FINDINGS OF FACT                                     
               Petitioners married on April 14, 1990, and remained married            
          from 1994 through 1997 (i.e., the years in issue).  Prior to                
          meeting Ruth A. Jenkins, James E. Jenkins (petitioner) made a               
          modest living in the flea market business.  Mrs. Jenkins was a              
          successful businesswoman and sole owner of Salvage Brokers,                 
          Limited, Inc. (Salvage Brokers), an auction and salvage business.           
          Petitioner and Mrs. Jenkins were president and secretary,                   
          respectively, of Salvage Brokers.  During the years in issue,               
          petitioners went on various gambling trips to Las Vegas, Nevada,            
          and Tunica, Mississippi, would typically take $1,500 for gambling           
          purposes, and had gambling losses in excess of their winnings.              
               Petitioner and Robert Hood were partners in ARJay Rentals              
          (ARJay).  Petitioner and Hood, through ARJay, assisted charities            
          in organizing and operating bingo games.  In exchange for their             
          services, the charities agreed to lease building space in which             
          to conduct the bingo games, purchase bingo equipment (e.g., bingo           
          cards), and split a percentage of the net profits with petitioner           
          and Hood.  ARJay’s receipt of a percentage of the net profits               

               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code in effect for the years in issue.                 




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