- 13 - For 1986, 1987, and 1988, Ms. Yue also prepared the Federal corporate income tax returns of the California corporations. During respondent’s audit for 1986, 1987, and 1988, and during the litigation of these cases, petitioner has been unable to obtain from Mr. Makalintal, who apparently has moved back to the Philippines, information and records pertaining to the bank accounts that Mr. Makalintal controlled and the purported sale of Mr. Makalintal’s 2 million shares of stock in ICPI. Based largely on petitioner’s inability to provide adequate information, respondent determined that Mr. Makalintal should be treated as having received in 1986 the entire $3 million stated sales price for the ICPI stock and as having no tax basis in the stock. Thus, respondent treated the entire $3 million stated sales price as additional net long-term capital gain for 1986. For 1987 and 1988, apparently based just on bank deposits analyses of the two bank accounts numbered 01150 and 01206 (limited information with respect to which petitioner was able to provide to respondent), respondent determined that Mr. Makalintal and petitioner realized unreported additional income of $690,922 and $969,584, respectively. Also for 1988, respondent determined that $31,335 was improperly claimed as a home mortgage interest expense deductionPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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