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