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corporate Federal income taxes and for tax evasion for 1984 and
1985 with regard both to petitioners' joint individual and CCMI's
corporate Federal income taxes.
On August 5, 1992, respondent determined deficiencies in and
additions to petitioners' joint Federal income taxes and CCMI's
corporate Federal income taxes for 1984 and 1985 in the total
amount of $299,908. The tax deficiencies and additions to tax
determined by respondent against petitioners for 1984 and 1985
bore no specific relationship to the offshore trust tax shelter
scheme at issue in this case but did relate to petitioners'
diversion of CCMI funds for their personal benefit in 1984 and
1985 through other schemes.
On October 17, 1991, petitioners paid to respondent the
total of $299,908 in Federal income tax deficiencies determined
against petitioners and CCMI for 1984 and 1985.
On October 22, 1991, petitioners each pleaded guilty to one
count of tax evasion for 1984. The Government dropped the
remaining counts of the above criminal indictment.
On March 16, 1993, respondent mailed to petitioners the
notice of deficiency for 1983 that is at issue in this case, in
which respondent determined that petitioners received in 1983,
not in 1982, unreported distributions from CCMI of $191,2783 as a
3 Respondent computed the $191,278 in distributions based on
the $184,630 withdrawn in 1983 from the Alpha account to purchase
the Oyster Pond Property, plus the $3,148 in furnishings paid
(continued...)
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