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(hereinafter respectively referred to as the 1987 return and 1988
return). Their 1987 return reported wage income of $90,611,
adjusted gross income of $92,522, and that petitioner’s
compensation from Gulf States Utilities was $41,782. Their 1988
return reported wage income of $85,862, adjusted gross income of
$87,092, and that petitioner’s compensation from Gulf States
Utilities was $41,604. Forms W-2 for the 1988 taxable year show
wages paid to Ms. Dawson by PAHHS and BHHS in the amounts of
$27,854 and $29,902.12, respectively. Such Forms W-2 include
$15,000 in wages from PAHHS and $15,000 in wages BHHS paid to Ms.
Dawson that were omitted from petitioner’s and Ms. Dawson’s
return for that year. Petitioner assisted Ms. Dawson in
preparing the 1988 return. The purported signature of petitioner
on the 1988 return is not in fact petitioner’s signature.
Petitioner filed a separate Federal income tax return for
the taxable year 1989 on May 21, 1990.
Certain Events Occurring Subsequent to the Years in Issue
Petitioner and Ms. Dawson separated on May 1, 1990, and were
divorced on December 4, 1990.
On or about July 8, 1991, Ms. Dawson pled guilty in the U.S.
District Court, Eastern District of Texas (District Court) to one
count of embezzlement, in violation of 18 U.S.C. sec. 666, and
one count of income tax evasion for the tax year 1988, in
violation of section 7201.
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