Adel Abdalla - Page 4

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                    (i) In an effort to avoid detection of the skimmed cash           
               receipts, petitioner purchased a large amount of his                   
               supplies with cash and only reported a portion of his cost             
               of goods sold during 1987 and 1988.                                    
                    (j) Petitioner fraudulently and with intent to evade              
               taxes, falsely informed his return preparer in 1987 and 1988           
               that all gross receipts and cost of goods sold were reported           
               on the original income tax returns, and that he had no                 
               additional income or expenses for those years.                         
                    (k) Petitioner Adel Abdalla's fraudulent                          
               understatements of his gross receipts and cost of goods sold           
               on his income tax returns for 1987 and 1988 is part of a two           
               year pattern of intent to evade taxes.                                 
                    (l) The petitioner fraudulently, and with intent to               
               evade taxes, omitted from his income tax returns for the               
               taxable years 1987 and 1988, substantial amounts of gross              
               receipts from his schedule C restaurant business, in the               
               amounts of $536,778.18 and $569,632.90, respectively.                  
                    (m) The petitioner fraudulently, and with intent to               
               evade taxes, omitted from his income tax returns for 1987              
               and 1988, substantial amounts of cost of goods sold from his           
               schedule C restaurant business, in the amounts of                      
               $352,534.64 and $382,706.67, respectively.                             
                    (n) A part of each deficiency in income tax for the               
               taxable years 1987 and 1988, is due to fraud with intent to            
               evade taxes.                                                           
               Petitioner filed a reply on May 17, 1995, wherein he denied            
          generally portions of respondent's answer relating to                       
          petitioner's alleged fraudulent conduct.  By notice dated July 7,           
          1995, the Court set this case for trial at the Philadelphia,                
          Pennsylvania, trial session beginning on December 11, 1995.  This           
          notice specifically stated that "YOUR FAILURE TO APPEAR MAY                 
          RESULT IN DISMISSAL OF THE CASE AND ENTRY OF DECISION AGAINST               
          YOU."                                                                       





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