- 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