J.J. Zand - Page 41

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          Naples.  Petitioner was a shareholder of the Riveria Condominium            
          Company of Naples.  In 1979 and 1980 petitioner owned two                   
          condominiums in the Riveria Condominium Complex.  Clem and                  
          Priscilla Meier also owned a condominium in the same area.                  
               Mr. Dinunzio was no stranger to petitioner.  In 1976, at age           
          20 and while still in college, Mr. Dinunzio married petitioner's            
          daughter, Sherie.  After graduating from college, he began                  
          working for some of the entities that petitioner controlled.  For           
          example, Mr. Dinunzio was vice-president of CDC, Caspian                    
          Machinery, Caspian Electric, and Caspian Florida.  Furthermore,             
          petitioner purchased a home in Columbus for Mr. Dinunzio and his            
          daughter.  Petitioner also provided Mr. Dinunzio with a Cadillac.           
               Mr. Dinunzio maintained diaries showing who used the                   
          condominium during the years 1979 and 1980.  Some of the persons            
          who used Mr. Dinunzio's condominium were employees of CDC, such             
          as Cindy Seaman, Celia Longenbaker, Priscilla Meier, Jane                   
          Kellermeyer, Steve Dutton, and Mr. Dinunzio; others who used the            
          condominium included business associates who wished to bid on               
          work that was to be done on a building being constructed by CDC,            
          clients of petitioner, and friends of Mr. Dinunzio.                         
               In addition, for the year 1980 petitioner substantiated                
          payments in the amount of $3,360.74 for Mr. Dinunzio's Florida              
          condominium.  However, petitioner deducted $4,022.68 with respect           
          to this condominium as rent expense.                                        





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