- 3 - Beginning in 1988, petitioners became involved in a complex and circuitous relationship with Joseph. Petitioners’ involvement with Joseph began with $30,000 and increased to over $200,000 by July 1990. The monthly "interest" paid by Joseph was either paid to petitioners or credited as an increase in their investment. Petitioners did not report any interest from these transactions on their Federal income tax returns, including the 1990 return. M&L also made payments totaling $10,000 toward petitioners' purchase of a motor vehicle. Also beginning sometime in 1988, petitioner became involved with Joseph/M&L in a check exchanging arrangement that ultimately became part of a check kiting scheme. M&L had cash-flow problems, and the goal of the scheme was to obtain some "float" in order to extend the time to pay commitments. The kiting also made it appear that M&L had more cash because of the inflation caused by the kiting activity. Under the arrangement, M&L would draw a check in favor of petitioner, and petitioner, in turn, would draw several checks totaling approximately the same amount to M&L. For 1989 and 1990, M&L's checks to petitioner exceeded petitioner's checks to M&L as follows: 1989 1990 Amount from M&L $5,866,328 $3,263,124 Amount to M&L 5,815,280 2,571,129 Excess received by petitioner 51,048 691,995Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011