- 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 NextLast modified: May 25, 2011