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the years at issue, was the superintendent in charge of the
Saltergate Village project.
Petitioner informed the other owners of Newtowne that he did
not want Forster working on the project. Petitioner indicated
that if Forster continued working on the project, he would
terminate the contract between the partnerships and Newtowne.
The parties finally agreed that Forster could remain on the
project if he purchased a Ford van for petitioner. Petitioner
also indicated that Forster could not write a company check for
this purchase. Instead, petitioner wanted Forster to pay for
this van using funds from his personal checking account.
In accordance with petitioner's instructions, Forster
presented petitioner with a check for $7,800 payable to a Ford
dealership. Petitioner invited his secretaries and other
employees into his office to witness the exchange. As Forster
handed him the check, petitioner announced: "I want to thank you
for this gift". Forster remained on the Saltergate Village
project, and Newtowne reimbursed him for the $7,800. Petitioner
did not report receipt of this van on his 1982 return.
4. Unreported Income From Savko
Respondent determined in the notice of deficiency that
petitioner failed to report $124,330 and $34,000 in income he
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