- 8 - Item 1987 1988 1989 Ordinary income from business activity $6,747 $7,280 $5,359 Guaranteed payment 29,900 32,900 31,500 Total 36,647 40,180 36,859 In 1990, petitioner was the target of a criminal investigation. Petitioner was charged with three counts of willfully and knowingly attempting to evade Federal income tax by filing false and fraudulent returns. Count 1 pertained to taxable year 1987, while the second and third counts pertained to taxable years 1988 and 1989, respectively. Petitioner entered a guilty plea to count 3. Petitioners concede that they underreported income in each taxable year at issue. Petitioners maintain, however, that the amount of unreported income for each taxable year at issue is equal to the amount of personal living expenses which petitioner paid by drawing checks against Fruitland's checking account, plus one-half of the cashier's checks purchased by petitioner during the taxable year, less one-half of the amount of cashier's checks negotiated during the taxable year, less the amount of income reported as received from Fruitland on petitioners' tax return. The following table illustrates petitioners' computation of unreported income for each taxable year at issue:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011