- 15 -
address on the account, and monthly bank statements were sent to
him there. Petitioner had sole check-signing authority.
During 1988 petitioners deposited $56,224 into the account.
No proceeds from the Iron Hill or Wayanne were supposed to have
gone into this account.
REP may stand for Real Estate Plus.8 Petitioner was the
actual and beneficial owner of R.E.P., LTD. Throughout 1987 and
1988, petitioners' home utility bills were in the name of R.E.
Plus. This was simply another name for petitioner.
We find and hold that petitioners had unreported income of
$130,232 for 1987 and $85,231 for 1988.
Petitioner did not cooperate during the audit. Although
requested to do so, he did not turn over any personal records to
respondent. He refused to pick up certified mail from the post
office. Moreover, he made false statements to respondent's
agent, Joanne Griffin. He claimed he had no bank accounts, no
credit cards, and no financial interest in any business during
1987 and 1988.
OPINION
The theme of this case could well be: "Oh, what a tangled
web we weave when first we practice to deceive."9 To that end,
8 REP may also stand for "Restaurant Equipment Properties".
9 Sir Walter Scott, "Marmion", canto VI, st. XVII (Little
Brown & Co. 1857).
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