- 7 - (2) paid and deducted the Gilchrists' personal expenses in the following amounts: Year Truck Expense Travel/Entertainment Utilities Total 1986 $1,317 $2,076 $3,782 $7,175 1987 2,907 4,513 11,858 19,278 1988 1,694 1,987 2,305 5,986 On their 1986, 1987, and 1988 individual returns, the Gilchrists reported gross income of $11,237, $13,144, and ($582), respectively. In each year, they reported that they received no dividend income. The parties, however, have stipulated: (1) Door Control made payments relating to the Gilchrists' personal expenses; (2) the Gilchrists deposited into their personal bank accounts corporate income of $94,983.42 in 1986, $66,173.01 in 1987, and $105,891.87 in 1988; and (3) the payments for personal expenses and diverted corporate income are taxable to the Gilchrists as constructive dividends. By information dated March 30, 1993, Mr. and Mrs. Gilchrist were each charged, pursuant to section 7206(1), with willfully making and subscribing a return which they did not believe to be true and correct. The information charged that each of them had willfully made and subscribed a Form 1040 for 1988 that they did not believe to be true and correct. It charged specifically that they failed to report diverted corporate income. Also on March 30, 1993, in accordance with a plea agreement, the Gilchrists each pleaded guilty to violation of section 7206(1). Pursuant to the plea agreement, the Gilchrists were required to payPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011