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sentenced to prison for a term of 30 months to run concurrently
with the sentence imposed by the State of Florida.
Mr. Fisher did not report the diverted proceeds on his
Federal income tax returns for 1991 and 1992. Using a bank
deposit analysis, respondent determined that Mr. Fisher failed to
report income from his illegal activities of $174,789 and
$118,401 for 1991 and 1992, respectively. As previously
indicated, petitioners do not contest respondent's determination
of deficiencies and additions to tax against Mr. Fisher.
Transfers of Real Property and Mortgage Payments
Mr. Fisher started planning the diversion of the telephone
commissions prior to June 1991. On June 6, 1991, Mr. Fisher
transferred to petitioners, by warranty deed, his interest in
three contiguous parcels of land located at 6913 Apalachee
Parkway, Tallahassee, Florida. These parcels consisted of a 2-
acre parcel (parcel 1), a 0.92-acre parcel (parcel 2), and a
0.25-acre parcel (parcel 3). On the date of these transfers,
there was only one improvement built on these parcels, which
consisted of a house constructed in 1989 on parcel 1. Mr. Fisher
applied for the construction permit for this house, and upon its
completion he moved into the house and continued to reside
therein until his imprisonment in 1993. The fair market value of
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