Charles E. Campbell - Page 11

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            narcotics, and car sales and repairs, and that petitioner                                    
            received unreported income from these activities.  Specifically,                             
            petitioner is deemed to have admitted under Rule 90(c) that:                                 
                        6.  During the taxable years 1987, 1988, and 1989,                               
                  [petitioner was] engaged in the following cash                                         
                  activities:                                                                            
                        a.  professional cardplayer;                                                     
                        b.  gambling;                                                                    
                        c.  sale of illegal narcotics; and                                               
                        d.  repair and sales of used automobiles.                                        
                  *      *       *        *        *       *       *                                     
                        23.  The total unreported gross income of                                        
                  [petitioner and his spouse] for the taxable year 1987                                  
                  is $126,845.94.                                                                        
                        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.                                                               







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