T.C. Memo. 1997-276 UNITED STATES TAX COURT TED W. GLEAVE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent 747 KENMORE AVE., INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 3586-87, 10512-89. Filed June 18, 1997. Individual petitioner (G) owned corporate petitioner (K). G caused K to write checks drawn against K’s account (1) to pay for investments and personal expenses of G, or (2) that were payable to cash or other. K filed tax returns for 1980, 1981, and 1982, but G did not. R used the bank deposits method and an analysis of checks disbursed in determining deficiencies against K. 1. Held: G and K are liable for additions to tax for civil fraud for 1980, 1981, and 1982. Secs. 6653(b) and 6653(b)(1), I.R.C. 1954. 2. Held, further, G and K are liable for additional additions to tax for 1982 based on the portion of the deficiencies attributable to fraud; amounts redetermined. Sec. 6653(b)(2) I.R.C. 1954.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011