- 14 - the money laundering scheme, Sam Gilbert Associates, Inc. (SGA), owned by Sam Gilbert, made payments to petitioner labeled "wages" on W-2 Forms and withheld taxes therefrom.14 In 1987, petitioner rendered services to Fort Apache, Inc., and received $17,000 wages, with taxes withheld. The Internal Revenue Service audited petitioner, first for 1986 and 1987, and then for 1985. During neither audit did petitioner produce the books and records necessary to substantiate items of income, gain, loss, or deduction. However, some documentation was given to respondent during the audits. On advice of counsel, petitioner did not cooperate with respondent during the audit for 1986 and 1987. Because of the lack of records and failure to cooperate by petitioner, respondent used the bank deposits method to determine petitioner's income for the 3 years at issue. During these 3 years, petitioner operated three bank accounts in his and Maxine's names: Safra Bank joint checking account (hereinafter Safra), Barnett Bank Joint Money Market Account (hereinafter Barnett money market), and Barnett Bank joint checking account (hereinafter Barnett joint checking). Safra was active beginning in December 1985, and closed in July 1987. The other two accounts remained open during the entire 3- year period. Safra, and to a lesser extent Barnett money market, 14The payroll checks from SGA, while not necessarily for services rendered, did provide support for petitioner during 1983-86.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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