Ronald L. Berkshire - Page 4

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                  the notice of deficiency upon which the instant case is                               
                  based.                                                                                
                        9.  FURTHER ANSWERING the petition, and in support                              
                  of the determination that a part of the underpayment of                               
                  tax for the taxable years 1985, 1986 and 1987 is due to                               
                  fraud, the respondent alleges:                                                        
                        (a)  On or about April 15, 1986, the petitioner                                 
                  with intent to evade and defeat income tax filed a 1985                               
                  joint income tax return (Form 1040) with the Internal                                 
                  Revenue Service that showed taxable income and taxes                                  
                  due in the amounts of $8,911.00 and $645.00,                                          
                  respectively.                                                                         
                        (b)  For the 1985 taxable year, the petitioner                                  
                  understated his taxable income by $52,322.00 and                                      
                  understated his 1985 income tax liabilities by                                        
                  $18,982.00.                                                                           
            *   *   *   *   *   *   *                                                                   
                        (k)  On or about April 15, 1986, the petitioner                                 
                  with intent to evade and defeat income taxes filed a                                  
                  1986 joint income tax return (Form 1040) with the                                     
                  Internal Revenue Service that showed taxable income of                                
                  $3,526.32 and no taxes due and owing for the year 1986.                               
                        (l)  For the taxable year 1986, the petitioner                                  
                  understated his 1986 taxable income by $75,753.00 and                                 
                  understated his 1986 income taxes by $22,471.00.                                      
            *   *   *   *   *   *   *                                                                   
                        (v)  The petitioner fraudulently and with intent                                
                  to evade tax omitted from his income tax returns for                                  
                  the taxable years 1985 and 1986, taxable income in the                                
                  respective amounts of $52,322.00 and $75,753.00.                                      
                        (w)  For the taxable year 1987, the petitioner                                  
                  failed to file a federal income tax return and paid no                                
                  federal tax for that year.                                                            
                        (x)  For the taxable year 1987, the petitioner                                  
                  received taxable income from UNICO, Inc. in a total                                   
                  amount of $111,195.00.                                                                
            *   *   *   *   *   *   *                                                                   





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