David Rendel and Rachel Rendel - Page 8

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                    transferred in 1982 into the offshore trusts was reflected as                                                                                          
                    taxable income to petitioners.                                                                                                                         
                              On September 14, 1983, Howard gave petitioners the proposed                                                                                  
                    amended 1982 return.  Petitioners, however, refused to sign the                                                                                        
                    proposed amended 1982 return, and Rachel tore it in two, stating,                                                                                      
                    "We'll wait until * * * [respondent] catches us."                                                                                                      
                              On petitioners' 1983 joint Federal income tax return that                                                                                    
                    was timely filed with respondent, neither the $174,308                                                                                                 
                    transferred out of CCMI through the offshore trusts and into the                                                                                       
                    Alpha account, nor the $184,630 withdrawn in 1983 from the Alpha                                                                                       
                    account and used by petitioners to purchase the Oyster Pond                                                                                            
                    Property was reported as income by petitioners.  On petitioners'                                                                                       
                    1983 Federal income tax return, petitioners did report as                                                                                              
                    miscellaneous income $21,058 relating to their personal use of                                                                                         
                    CCMI funds.  This amount was not otherwise described.                                                                                                  
                              On CCMI's 1983 Federal corporate income tax return, $3,158                                                                                   
                    in interest income earned on the Alpha account in 1983 was                                                                                             
                    reported as interest income.                                                                                                                           
                              On November 24, 1984, Howard, as trustee for Alpha, and                                                                                      
                    without consideration, signed a reconveyance deed transferring                                                                                         
                    Alpha's purported security interest in the Oyster Pond Property                                                                                        
                    from Alpha to petitioners.                                                                                                                             
                              On April 10, 1991, a Federal Grand Jury indicted petitioners                                                                                 
                    for conspiracy to defraud the United States during 1981 through                                                                                        
                    1986 with regard to petitioners' joint individual and CCMI's                                                                                           




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