T.C. Memo. 1996-528 UNITED STATES TAX COURT KHOSROW GHADIRI AND TURAN MIRHADY GHADIRI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14817-95. Filed November 27, 1996. Ps operated the Maple Press and Acacia Press print shops during 1986 and 1987. Ps operated the Maple Press, Acacia Press, and Print Technology print shops during 1988. During all 3 years, Ps deposited the proceeds from the print shops into bank accounts. 1. Held: Ps must include in income the portion of Maple Press, Acacia Press, and Print Technology bank deposits which did not represent gross receipts reported, insufficient funds checks, bank debits, or interaccount transfers. 2. Held, further, R is not barred by the period of limitation from assessing tax for Ps' 1988 taxable year. 3. Held, further, Ps are liable for additions to tax under sec. 6651(a)(1), I.R.C., for all years in issue. 4. Held, further, Ps are liable for additions to tax under sec. 6653(a)(1)(A) and (B), I.R.C., for 1986 and 1987, and under sec. 6653(a)(1), I.R.C., for 1988.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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