- 19 - Petitioners never reported any of CAI's funds used by them as income on a personal tax return. The total amount of CAI funds in the A, C, and set-off accounts used for petitioners' benefit totaled $705,107.17 Of this amount, $245,008 was used in 1980, $312,269 was used in 1981, and $147,830 was used in 1982. Petitioner was aware that he could be charged with income from CAI and the resulting tax liability. 6. Reporting Requirements Petitioners' 1980 through 1982 tax returns were prepared by their accountant, Seymour Schiller (Mr. Schiller). In connection with the preparation of those returns, petitioner did not tell Mr. Schiller that petitioners had an interest in a foreign account during the relevant years. Petitioners indicated on their 1980 and 1981 tax returns that they did not have such an interest during 1980 and 1981. Petitioners did not report on their 1982 tax return that they had an interest in a foreign account during 1982. Petitioners had an interest in CAI's bank account during each of the subject years. 7. Mrs. Fields Mrs. Fields is an educated woman, and she has been involved in the business world in a limited capacity. She received a 17 Respondent seeks to include only $669,124 of this income in petitioners' gross income.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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