Robert D. Grossman, Jr. - Page 136

                                       - 79 -                                         

          No. 121 on her checking account for $13,167.96 as a payment of              
          interest on the loan and delivered it to Brown sometime between             
          December 22, 1987, and February 12, 1988.  The check was dated              
          December 22, 1987.  The check was posted to Markette’s bank                 
          account on February 12, 1988, and to Betsy’s checking account on            
          February 16, 1988.  Betsy wrote checks in her checking account in           
          numerical order.  Check No. 120 was recorded on Betsy’s checking            
          account register on November 30, 1987, and check No. 122 was                
          recorded on June 25, 1988.                                                  
               Starting in December 1987, Betsy and Brown began to pack up            
          the Sley Corporations books and records in boxes because they               
          were going to move the Sley Corporations office out of the                  
          Grossman & Flask sublet office space.  Betsy arranged to have               
          professional movers move the Sley Corporations office on January            
          13, 1988.                                                                   
               On their 1987 joint tax return, petitioner and Betsy listed            
          a $13,168 personal interest expense to Markette and deducted 65-            
          percent of it--$8,559--as an itemized deduction on Schedule A.              
               Respondent disallowed this deduction.                                  
                                                                                     
               For each of the years 1983 through 1986, petitioner had an             
          underpayment of income tax required to be shown on his tax                  
          return; some part of the underpayment for each of the years 1985            
          and 1986 was due to petitioner’s fraud.                                     





Page:  Previous  69  70  71  72  73  74  75  76  77  78  79  80  81  82  83  84  85  86  87  88  Next

Last modified: May 25, 2011