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Distributions from particular line items in the construction
budgets were also made to petitioner before cost savings were
computed. Such distributions were known internally as "owner's
check request(s)". On August 31, 1983, for example, an owner's
check request was issued to petitioner from Newtowne in the
amount of $20,496.58. This amount is not reflected on
petitioner's 1983 return. Petitioner failed to attach to that
return a schedule indicating how he determined his gross receipts
for 1983. Petitioner prepared a document entitled "1099 Income"
which purports to reflect amounts he received during 1983 for his
financial consulting services. This document was not presented
to Meeks when he reviewed petitioner's return for that year. The
owner's check request is not reflected on this document.
Petitioner's 1984 return does not reflect the amounts he
received from Newtowne in cost savings. As indicated, petitioner
attached a schedule to his 1984 return which itemized the income
he received from "Financial Consulting". The schedule does not
state that he received payments from Newtowne. Petitioner
reported "other consulting fees" on the schedule in the amount of
$180,000. It is unclear whether "other consulting fees"
represents the amounts petitioner received from Newtowne for his
consulting services, cost savings, or a portion of the cost
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