Adel Abdalla - Page 3

                                        - 3 -                                         

                    (a) During each of the taxable years 1987 and 1988, the           
               petitioner owned and operated Papa's Restaurant in                     
               Schnecksville, Pennsylvania, a sole proprietorship.                    
                    (b) During the taxable years 1987 and 1988,                       
               petitioner's restaurant earned gross receipts of $900,510.38           
               and $977,136.00, respectively.  On his original income tax             
               returns for 1987 and 1988, petitioner reported gross                   
               receipts of $363,732.00 and $407,503.10, respectively.                 
                    (c) During the taxable years 1987 and 1988,                       
               petitioner's cost of goods sold were $466,628.78 and                   
               $514,119.57, respectively.  On his original income tax                 
               returns for 1987 and 1988, petitioner reported cost of goods           
               sold of $114,094.14 and $131,412.90, respectively.                     
                    (d) The petitioner understated his taxable income on              
               his income tax returns for the taxable years 1987 and 1988,            
               in the amounts of $192,429.16 and $193,253.20, respectively.           
                    (e) The petitioner understated his income tax                     
               liabilities on his income tax returns for the taxable years            
               1987 and 1988 in the amounts of $68,912.50 and $62,153.90,             
               respectively.                                                          
                    (f) Petitioner Adel Abdalla fraudulently and with                 
               intent to evade taxes for the taxable years 1987 and 1988,             
               filed false income tax returns for said years that omitted             
               the skimmed cash receipts and understated cost of goods                
               sold.                                                                  
                    (g) Respondent's determination of the omission of                 
               income and cost of goods sold is corroborated by the fact              
               that petitioner filed two documents captioned "Amended                 
               United States Individual Income Tax Returns" for the years             
               1987 and 1988 with the Internal Revenue Service Center in              
               Philadelphia, Pennsylvania including all the omitted income            
               for these years.  These amended returns were received at the           
               Internal Revenue Service Center on December 4, 1989.  Said             
               documents were not sent to the Internal Revenue Service                
               Center until the Examination Division had contacted the                
               petitioner regarding his 1987 and 1988 federal income tax              
               returns.                                                               
                    (h) Respondent's determination of the understatement of           
               cost of goods sold has also been corroborated by documenting           
               cost of goods sold through contact with petitioner's                   
               suppliers.                                                             




Page:  Previous  1  2  3  4  5  6  7  8  Next

Last modified: May 25, 2011