Joseph T. Walker and Nancy Walker - Page 18

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     represented both Mr. and Mrs. Walker from March 19, 1990 through April           
     14, 1993, ceased his representation of them pursuant to leave of this            
     Court, and then resumed being counsel solely to Mrs. Walker on                   
     February 3, 1994.                                                                
          On August 30, 1990, Mr. and Mrs. Walker filed a motion to                   
     suppress all evidence obtained from grand jury materials. This Court             
     denied their motion on February 5, 1992. See Walker v. Commissioner,             
     T.C. Memo. 1992-54.                                                              
          Sometime in October 1993, during the course of pretrial discovery           
     conducted by respondent, Mr. and Mrs. Walker for the first time                  
     asserted that Mrs. Walker had not signed the 1978, 1979, 1980, and               
     1981 returns. In their responses to certain other interrogatories                
     served upon them by respondent, they also denied that, during or after           
     the years in issue, Mr. Walker (1)                                               
     transferred any assets of over $500 (other than for certain                      
     automobiles) to Mrs. Walker; and (2) made any gifts to her.                      
                                     OPINION                                          
     Mr. Walker's Unreported Taxable Income                                           
          The parties agree that, during 1978 through 1981, Mr. Walker                
     diverted and received from West Jersey the funds determined in our               
     findings. They also agree that these diverted funds, less amounts Mr.            
     Walker used in purchasing cashier checks for Simmel and the boat for             
     Short, represent unreported taxable income of Mr. Walker for 1978,               
     1979, 1980, and 1981, except to the extent of additional cash payments           
     that Mr. Walker can establish were made by him "to (or for the direct            
     benefit of)" Short and Simmel                                                    



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