J.J. Zand - Page 12

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          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.                                                        





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