- 52 - 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.Page: Previous 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Next
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