- 101 - Federal income tax returns. Petitioner did not disclose the existence of foreign bank accounts in his name on those returns or on the two amended 1975 returns filed in 1976 and 1978. Mr. Giffin, who prepared petitioner's 1974 and 1975 tax returns, was not aware that the FNCB account in London existed. Furthermore, employees of CTC were not aware that some of the foreign bank accounts in petitioner's name existed. In 1976 petitioner earned interest on an FNCB account, number 245925, in the amount of �27,466.39. During 1976 he also received payments from Crown Life of $459.05, which were recorded as dividends in CTC's cash receipts journal. Petitioner did not include either the interest on the FNCB account or the dividends from Crown Life on 1976 Federal income tax return. On Form 4683 filed with his 1976 return petitioner reported that his financial interest in FNCB account number 245925 did not exceed $50,000. However, during 1976 General Motors paid over $140,000 into FNCB account number 245925. Petitioner's employee requested these deposits. To Diesel Power and to third parties (including General Motors and Clark), CTC employees referred to FNCB accounts numbers 1217690 and 245925 as petitioner's accounts. Petitioner offered no documentation, such as statements or policy notices, that the amounts paid to him by Crown Life were returns of premiums.Page: Previous 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 Next
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