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Some of the facts have been stipulated and are so found.
The stipulations and the exhibits attached thereto are
incorporated herein by this reference. Petitioners resided in
San Jose, California, when they filed their petition.
During petitioners' 1986, 1987, and 1988 taxable years, they
owned and operated print shops known as "Maple Press" and "Acacia
Press". During petitioners' 1988 taxable year, they also owned
and operated a print shop known as "Print Technology".
Petitioners did not keep books or records for any of these print
shops. During 1986 and 1987, petitioners' only sources of income
were Maple Press, Acacia Press, and Mr. Ghadiri's teaching
position, which paid him less than $5,000 per year. During 1988,
petitioners' only sources of income were Maple Press, Acacia
Press, Print Technology, and Mr. Ghadiri's teaching position,
which paid him less than $5,000.
Petitioners reported Mr. Ghadiri's teaching income on their
tax returns for the respective years. Petitioners hired Peter A.
Balbiani, a certified public accountant, to file their Federal
income tax returns for 1986, 1987, and 1988. For 1986, 1987, and
1988, the record contains no copies of deposit slips for the bank
accounts into which the gross receipts of petitioners' print
shops were deposited.
During 1986, petitioners made the following deposits and
reported on their tax return the following gross receipts from
Maple Press and Acacia Press:
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