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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.
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