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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.
3(...continued)
he willfully and knowingly attempted to evade taxes.
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