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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.
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