- 50 -
We conclude that respondent has met her burden of proving
that $624,000, $806,076, and $273,700 in partnership fee income
for 1982, 1983, and 1984, respectively, is attributable to fraud.
In an attempt to camouflage or conceal his receipt of the
partnership fee income, petitioner entered into complex
transactions with numerous partnerships. Despite the written
agreements petitioner entered into with the partnerships,
petitioner failed to report as income the fees he received for
the contracted services. Petitioner's failure to accurately
report receipt of these funds was due to fraud.
(2) Newtowne
We have concluded that petitioner failed to report income he
received from Newtowne in the amounts of $31,014 and $1,272,500
on his 1982 and 1983 returns, respectively. We have also
concluded that petitioner failed to report income from the
Saltergate I project in the amount of $120,000 on his 1982
return. Respondent asserts that $151,01410 and $1,282,500 for
1982 and 1983, respectively, is attributable to fraud.
10 Respondent determined that petitioner failed to report
$31,014, or the difference between $158,000 and the amount
reported on his 1982 return, $126,986. We added the $120,000
that petitioner failed to report from the Saltergate I project to
the $31,014 for a total of $151,014. The $7,800 petitioner
received for the Ford van is discussed infra.
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