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(...continued)
ad, and ae of paragraph 7 of respondent's amended answer provide:
(k) Petitioners refused to make available to
agents of the respondent any records concerning their
individual income tax liabilities for the taxable years
1975, 1976 or 1977.
(l) Petitioners furnished only incomplete records
of their corporations Ezy Parks, Inc., Tumble Down,
Inc. and Ezy Parks II, Inc. to agents of the respondent
for the taxable years 1975, 1976 and 1977.
* * * * * * *
(o) Petitioners did not have available on
December 31, 1974 any cash on hand which was not
deposited in one of petitioners' bank accounts.
(p) There is attached hereto as Exhibit A, which
is incorporated herein by reference and made a part
hereof, a statement summarizing petitioners [sic] net
worth increases and non-deductible expenditures for
each of the taxable years 1975, 1976 and 1977.
* * * * * * *
(r) Petitioners owned all of the stock and
completely controlled Jay Faunce, Inc.
(s) Jay Faunce, Inc. did not actively conduct any
business activities at any time.
(t) The sole function of Jay Faunce, Inc. was to
acquire and hold title to real estate properties
acquired by petitioners with unreported income.
(u) Petitioners used unreported income to acquire
eight real estate properties in their names or the name
of a wholly owned nominee corporation.
(v) During the taxable years 1976 and 1977,
petitioners acquired at least six real estate
properties which they concealed by holding title for
these properties in the name of their nominee
corporation Jay Faunce, Inc.
(continued...)
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