- 11 -
1970 $2,484
1971 1,601
1973 646
1974 260
1975 -0-
1976 514
1977 135
1978 2,248
1979 -0-
1980 -0-
On Martin and petitioner's joint Federal income tax returns
for 1981, 1982, 1983, and 1984, none of the funds embezzled by
Martin were reported.
Martin claimed on his and petitioner's 1983 joint Federal
income tax return a deduction of $600,000 reflecting the above-
referenced contribution into a Keogh plan.
For years prior to 1981, Martin and petitioner were audited
three times by respondent regarding their Federal income tax
liabilities, including for 1979 a detailed, line-by-line audit
under respondent’s taxpayer compliance measurement program
(TCMP). Each of these audits was resolved with minimal
adjustments; one or more of such adjustments were in Martin and
petitioner's favor. At the conclusion of the TCMP audit for
1979, petitioner was correctly informed by Martin that respondent
had made no adjustment to their 1979 joint Federal income tax
return.
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