Henry Deletis, Jr. - Page 7

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          Bud-N-Jan Stables, Inc.                                                     
               In late 1966, petitioner and his then wife, Janet Singer               
          Deletis (Singer), organized Bud-N-Jan Stables, Inc. (the Stables)           
          for the purpose of racing horses.  Petitioner and Singer were the           
          only two stockholders.  Petitioner was president and treasurer of           
          the Stables until December of 1967.  The Stables had a bank                 
          account at Bankers Trust Company.  The Stables owned about 12               
          horses worth almost $40,000 located in Maryland.  The Stables               
          used the services of three trainers:  P.J. Johnson, Mario                   
          Padoranni, and Oliver Cutshaw.  During 1967, the Stables raced              
          its horses and won race purses totaling $39,304.  The Stables did           
          not file a Federal corporate income tax return for the taxable              
          year 1967.                                                                  
               Petitioner invested some of the proceeds from the stolen car           
          sales into the Stables.  Petitioner contends that the only                  
          portion of the car sales proceeds that he kept was the $40,000              
          that he invested in the Stables.  See supra note 3.  Petitioner             
          testified that he agreed to give the Stables to Caplan to pay off           
          the money petitioner stole from the dealership, but that in                 
          December of 1967, Singer "stole" the Stables from him before he             
          could do so.  Petitioner signed an agreement whereby petitioner             
          transferred his interest in the Stables to Singer in exchange for           
          promissory notes; however, petitioner never received the notes.             

          he willfully and knowingly attempted to evade taxes.                        

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