William C. Beretta - Page 3

                                                - 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

Last modified: May 25, 2011