Albert J. and Helen R. Desantis - Page 52

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          Petitioner's failure to report this amount, and the method he               
          utilized to obtain the $120,000, clearly indicate his intent to             
          conceal his receipt of this income.  Respondent has met her                 
          burden of proving that $151,014 and $1,272,500, for 1982 and                
          1983, respectively, is attributable to fraud for section                    
          6653(b)(2) purposes.                                                        
                    (3)  Park Place                                                   
               Respondent alleges that petitioner failed to report $180,000           
          in income from Newtowne and the Park Place partnership on his               
          1984 return.  Petitioner reported $30,525 in income from the Park           
          Place partnership on his 1984 return.                                       
               Petitioner caused checks to be drawn on the Park Place,                
          Ltd., partnership account totaling $180,000.  These checks were             
          made payable to Newtowne and were presented to Fankhauser with              
          the following preprinted endorsement:  "Pay to the Order of                 
          Albert J. DeSantis in Partial Payment of Consulting Services".              
          It was agreed that petitioner would not provide Newtowne with the           
          consulting services as indicated on the checks.  Petitioner sent            
          the checks by messengers to Newtowne's office where they waited             
          for Fankhauser's endorsement before returning the checks to                 
          petitioner.  Petitioner deposited the checks into his personal              
          checking account at BancOhio.                                               








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