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Goings was indicted under section 7206(1) for two counts of
filing false Federal income tax returns for taxable years 1987
and 1988. It was the omission of the income received from
Bordelon from the couple's joint returns that gave rise to this
indictment. In January 1994, Mr. Goings entered a guilty plea to
both counts. His sentence included an 11-month prison term.
During the course of the criminal proceedings, Mr. Goings
admitted to receiving the $1,047,000 in income described above
from Bordelon.
In April 1991, petitioner and Mr. Goings formed an
irrevocable trust (the trust), transferring three parcels of real
property and several items of equipment to the trust. The
couple's three children were the beneficiaries of the trust.
Of the three parcels of real estate transferred to the trust, one
was purchased in November 1981 for $26,000, one was purchased in
September 1987 for $315,000, and one was purchased in November
1989 for $15,000. In 1991, petitioner transferred real property
worth $146,280 to the trust. Between 1992 and 1994, Highland
paid the following amounts of rent to the trust for use of
various pieces of equipment and the real property described above
as having been purchased in 1987 for $315,000:
Year Amount
1992 $40,940
1993 28,223
1994 49,038
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