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other subparagraphs in paragraph seven are amply supported by the
record,2
(...continued)
(w) Petitioners deposited unreported income into
34 bank accounts in twelve different banks during the
taxable years 1975, 1976 and 1977.
* * * * * * *
(y) Petitioners' adjusted gross income as
determined by petitioners' net worth increases and non-
deductible expenses was $127,762.80 for 1975,
$322,213.21 for 1976, and $211,173.54 for 1977.
(aa) Petitioners' correct taxable income was
$121,494.80 for 1975, $314,232.21 for 1976, and
$206,568.44 for 1977.
(ab) Petitioners with fraudulent intent to evade
tax substantially understated their income for the
taxable years 1975, 1976 and 1977.
(ac) Petitioners fraudulently with intent to
evade tax failed to report $93,071.80 of taxable income
for 1975, $276,309.21 of taxable income for 1976, and
$148,035.54 of taxable income for 1977.
(ad) Petitioners fraudulently with intent to
evade tax understated their tax liabilities by
$51,271.70 on their 1975 income tax return, by
$157,706.46 on their 1976 income tax return, and by
$93,536.23 on their 1977 income tax return.
(ae) A part of the underpayment of tax required
to be shown on the petitioners [sic] income tax returns
for their 1975, 1976 and 1977 taxable years is due to
fraud.
2 The following subparagraphs of paragraph seven are
supported by the record and the findings of fact in our prior
opinion:
(a) Petitioners Leon Spear and Jeanette Spear
were married individuals during the years 1975, 1976
and 1977.
(continued...)
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