- 7 - Petitioner's total cash expenditures during 1986 equaled at least $126,911. Petitioner filed his 1986 return on or after December 1, 1988. In that return, petitioner reported that he received the following items of gross income from the payors indicated: Payors Amount Mingles, Inc. $3,651.50 Eduardo, Inc. 298.07 Eduardo, Inc. 1,400.00 Britex, Inc. T/A Linea Pitti 457.14 C & I, Inc. T/A Linea Pitti 3,542.86 State and local income tax refund 258.00 Total 9,607.57 During 1986, petitioner received $26,000 in gross income from operating a car wash business that his father and he owned and that was known as Custom Car Salon. Petitioner did not report any portion of that $26,000 in the return that he filed for 1986. Petitioner did not maintain any books or records for 1986 relating to his income-producing activities. In examining petitioner's taxable year 1986, respondent reconstructed peti- tioner's income pursuant to the cash expenditures method and determined in the notice of deficiency (notice) that petitioner had unreported income of $122,461 for that year. On May 25, 1989, a Federal grand jury indicted petitioner on, inter alia, over 50 counts of violating 18 U.S.C. sections 1956(a)(1)(B)(i) and 1957 (1994) involving the laundering of proceeds of specified unlawful activity and criminally derivedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011