- 4 - Cena did not file a Form 1065, U.S. Partnership Return of Income, for the year 1985. Cena had gross receipts of $24,463 for the year 1985. Petitioner and Daro each reported $12,216 of Cena's gross receipts on their 1985 individual Federal income tax returns.3 On May 9, 1985, petitioner and Daro opened a joint bank account at Norbank, North Kansas City, Missouri (Norbank), in the name of petitioner and Daro doing business as "Orad Associates" (Orad account and Orad). The signature cards for the Orad account bear the signatures of both petitioner and Daro. Included in the records of the Norbank account was a document entitled "Partnership Certificate" for the "General Co- partnership known as Orad Associates." Although Daro signed the aforementioned partnership certificate, she testified that she was not a partner in Orad. Furthermore, she testified that she had nothing to do with Orad, and that petitioner operated Orad exclusively. During 1985, $20,971 was deposited into the Orad account. With the exception of a $500 deposit (which was made from petitioner's personal bank account at Norbank) and a $2,000 deposit (which was made by Cena), all the remaining deposits into the Orad account were from Knappco, payable to Orad. The checks from Knappco, payable to Orad, were all signed by petitioner, 3 The record does not establish why petitioner and Daro included only $12,216 each on their returns, when one-half of Cena's $24,463 of gross receipts is $12,231.50.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011