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24. [Petitioner's] share of the total unreported
gross income for 1987, under the community property
laws of Texas, is $63,422.97.
25. The total unreported gross income for
[petitioner and his spouse] for the taxable year 1988
is $108,438.07.
26. [Petitioner's] share of the total unreported
gross income for 1988, under community property laws of
Texas, is $54,219.04.
27. The total unreported taxable income for
[petitioner and his spouse] for the taxable year 1989
is $47,968.80.
28. [Petitioner's] share of the total unreported
gross income [for 1989], under the community property
laws of Texas, is $23,984.40.
* * * * * * *
32. [Petitioner's] correct tax liability,
including self-employment tax, for the taxable years
1987, 1988, and 1989, is $23,320.00, $18,554.00, and
$9,658.00, respectively.
33. [Petitioner has] not made any payments of tax
for the income tax liabilities due for 1987, 1988, or
1989.
34. [Petitioner's] failure to file a federal
income tax return for each of the taxable years 1987,
1988, and 1989, was fraudulent with the intent to evade
the payment of taxes on taxable income earned in each
respective year.
35. [Petitioner] failed to maintain complete and
adequate records of the activities [he] conducted in
cash during the taxable years 1987, 1988, and 1989,
with the intent to evade the payment of taxes on such
business transactions in each respective year.
36. [Petitioner] failed to produce any records of
[his] business or personal activities for respondent
during the examination of [his] income tax liabilities
for the taxable years 1987, 1988, and 1989.
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