- 8 -- 8 - 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neither the $174,308 transferred out of CCMI through the offshore trusts and into the Alpha account, nor the $184,630 withdrawn in 1983 from the Alpha account and used by petitioners to purchase the Oyster Pond Property was reported as income by petitioners.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'sPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011