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1992 Form 1040, U.S. Individual Income Tax Return, using the
filing status of "Single".
Petitioner has worked installing floors since 1968. Before
1990, he worked as a sole proprietor; for 1989, his sole
proprietorship reported gross receipts of $64,081 and net income
of $29,236. During 1992, petitioner purportedly installed floors
in his capacity as general manager of a trust entitled Ideal
Management. Ideal Management's sole beneficiary was purportedly
Clark Co. (Clark), a foreign trust based in Gibraltar in 1992,
and in Belize City, Belize, C.A., in 1990 and 1991. Clark's sole
beneficiary was purportedly Arlington Co. (Arlington), a
third-tier trust with a trustee named Dennis Smith. The 1992
business address and phone number of Arlington, Clark, and Ideal
Management were listed respectively as petitioner's home address
and petitioner's home phone number. Clark did not file a Federal
tax return, or pay Federal income tax, for any of the relevant
years.
On or before April 3, 1989, petitioner paid $2,500 to the
International Businessmen's Association (IBA) for documents to
join Ideal Management. Ideal Management was purportedly formed
by Cache Properties, Unlimited (Cache), with the transfer of $100
on January 12, 1989, and IBA's corepresentative at that time was
Alex Yung. Mr. Yung, who also was Ideal Management's first
trustee, was convicted of conspiring to defraud the United States
by impeding, obstructing, and defeating the Internal Revenue
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