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will also need the cost and selling price of any assets
you disposed of in 1991. I am equally concerned that
your not having a personal set of books will only add
to confusion in the future. I am aware of a number of
asset disposals you have made so far this year. These
items are business transactions that will need to be
reported for tax purposes but I am concerned that,
without a set of books, it will be much more difficult
to prepare an accurate tax return next year with a
minimal amount of time and effort.
Esquivel and G. Rodriguez compiled a list of all of the
items in petitioner's home. The list included a description of
the items, the quantity of items, and the value of the items.
On July 31, 1992, petitioner filed with the clerk of Bexar County
in San Antonio, Texas, a Uniform Commercial Code (UCC) financing
statement. Attached to the financing statement was the list of
petitioner's household items, a security agreement between
petitioner and his wife, and a note between petitioner and his
wife. The security agreement granted petitioner's wife a
security interest in petitioner's household items. The security
interest was granted in exchange for petitioner's obligation to
pay his wife $214,149.76, purportedly represented by the note.
Petitioner's 1990 Federal income tax return was prepared by
Boldt. The return showed no wage income, interest income of
$21,597, adjusted gross income of $3,722, itemized deductions of
$87,485, and zero tax owing. Petitioner subsequently amended his
1990 return to add Mexican wages of $6,398 and a Mexican tax
refund of $497. The total tax due after the amendment remained
zero. Petitioner's 1991 Federal tax return was prepared by
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