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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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