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James E. Hall and/or Gulf Coast Construction[4] for fees for
construction consulting, materials and commissions" in the
following amounts:
Amount
Year Received
1989 $142,377.00
1990 76,450.00
1991 180,608.50
Total $399,435.50
In February 1993, Mr. Clark prepared Forms 1099 for Mr.
Hall. Shortly thereafter, petitioner received Forms 1099 for
1989, 1990, and 1991 from Mr. Hall. These Forms 1099 reflect the
same amounts as stated in petitioner's affidavit signed in
November 1992.
Mr. Givens ascertained that the payments from Mr. Hall had
not been reported on petitioner’s original Federal income tax
returns. Mr. Givens spoke with petitioner on February 3, 1993,
by telephone. During this conversation, Mr. Givens identified
himself and requested a meeting with petitioner the following
day, February 4, 1993. Mr. Givens advised petitioner that his
returns for 1989, 1990, and 1991 were under examination and to
bring copies of his tax returns for those years and all records
available that were used to prepare them. Petitioner
4There is no explanation in the record regarding Gulf Coast
Construction. However, we assume that it was a business name for
Mr. Hall, since petitioner has stipulated that these amounts were
received from James Hall.
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