Patricia S. Makalintal - Page 13

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               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 deduction            









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