- 3 - FINDINGS OF FACT1 At the time the petition in this case was filed, petitioner, Mr. William Beretta, resided in Salinas, California. Petitioner claimed head of household filing status for each of the years at issue. 1. Skimmed Proceeds Mr. Beretta was employed by the Internal Revenue Service (IRS), Collection Division, from 1965 to 1994, as a revenue officer. Mr. Beretta was trained to identify tax examination situations and to inform taxpayers of their obligation to pay taxes. In particular, Mr. Beretta conducted investigations of taxpayers who had failed to file tax returns. In addition to his employment with the IRS, Mr. Beretta also invested in several restaurants. During the years at issue, petitioner owned an interest in three restaurants: The Salinas Peppertree Restaurant, the Seaside Bobby Rodgers Steak and Gourmet Burgers, and the Atascadero Peppertree Restaurant. Mr. Beretta was a principal in a corporation known as HRB Enterprises, Inc. (HRB Enterprises). The three principals in the corporation were Randy Hurst (H), Bobby Rodgers (R) and Mr. Beretta (B). HRB Enterprises operated various restaurants in Atascadero, Fresno, and Salinas, California. On August 14, 1984, 1 The stipulation of facts and the attached exhibits are incorporated by this references.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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