Door Control Services, Inc., et al. - Page 7

                                        - 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 pay                     





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  Next

Last modified: May 25, 2011