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expense checks Mr. Gaskins received from West Pine from June of
1979 through September of 1981. When the Gaskins were first
married, they had a joint checking account; a year or two later,
this was changed into Mrs. Gaskins' name only, since she paid
all the bills. To Mrs. Gaskins' knowledge, Mr. Gaskins did not
have a checking account or other bank accounts thereafter. For a
short time in the late 1960's, the Gaskins had had a savings
account containing approximately $800 received as wedding gifts.
As far as Mrs. Gaskins knew, the Gaskins had no other bank
accounts between 1972 and 1981. For the years at issue, Mrs.
Gaskins did not prepare the Gaskins' Federal individual income
tax returns, but she assembled the information for preparation
of the returns and met with the tax return preparer.
Prior Tax Liabilities
Mrs. Gaskins first learned of the employment tax problems
with the first roofing company in 1975 or 1976 when the Gaskins
incorporated the second roofing company. Mrs. Gaskins then
learned that Mr. Gaskins had received letters from the IRS,
mailed to the first roofing company's office, requesting payment
of these taxes.
Mr. Gaskins also had problems with his individual Federal
tax returns for taxable years 1970 through 1974. The IRS
assessed a fraud penalty against Mr. Gaskins with respect to his
individual tax deficiencies. Beginning in late December of 1981
through May of 1982, the IRS sent several notices to Mr. Gaskins
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