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.
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