Door Control Services, Inc., et al. - Page 6

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               Subsequent to the discovery of the undisclosed personal                
          accounts, Revenue Agent Caid and Special Agent Chisenhall of the            
          Internal Revenue Service's Criminal Investigation Division met              
          with the Gilchrists and examined all of petitioners' bank                   
          records.  The agents found that Door Control failed to report,              
          and diverted into the Gilchrists' personal accounts, corporate              
          income of $94,983.42 in 1986, $66,173.01 in 1987, and $105,891.87           
          in 1988.  The Gilchrists had not provided Mr. Crim with any                 
          information concerning this income.                                         
               On May 25, 1990, the Gilchrists met with Revenue Agent Caid            
          and Special Agent Chisenhall and agreed to write and sign                   
          affidavits.  Mr. Gilchrist admitted in his affidavit:  (1) Door             
          Control's 1986, 1987, and 1988 corporate returns were "not true,            
          correct, and accurate"; (2) he and Mrs. Gilchrist misclassified             
          personal expenses as business expenses; (3) Door Control paid and           
          deducted personal expenses of the Gilchrists; and (4) on                    
          individual returns for 1986, 1987, and 1988, he failed to report            
          personal income but deducted associated expenses.  Mrs. Gilchrist           
          adopted Mr. Gilchrist's statement in her own affidavit.                     
               On its 1985, 1986, and 1987 corporate returns, Door Control            
          carried back a net operating loss from 1988 and deducted a                  
          portion of this loss on each return.  In addition, on its 1986,             
          1987, and 1988 corporate returns, Door Control (1) reported                 
          taxable income of $0, $6,997, and ($22,932), respectively, and              






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