Ted W. Gleave - Page 1

                                 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.                                           






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