- 4 -
(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."
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011