- 4 - Locksmith operated, and the corporation paid them $1,500 per month rent. On the 1983 joint return, petitioner and Emmens reported rental income from Nelson Locksmith of $12,301.2 Emmens sold Nelson Locksmith in January 1984. On their 1984 joint return, petitioner and Emmens reported a $20,753 gain attributable to the sale of the business and rental income of $2,243. Petitioner was an authorized signatory on the bank accounts of Nelson Locksmith. Additionally, petitioner occasionally wrote checks on this account for both business and personal purposes. Criminal Activity During the years in issue, Emmens was involved in narcotics trafficking. He and various other individuals, including John Sydoriak (Sydoriak) and Vincent Kadyszewski (Kadyszewski), smuggled substantial amounts of marijuana and cocaine into the United States from the Bahamas. The typical narcotics transaction would proceed as follows. Three boats would depart from Delray Beach, Florida (Delray Beach), and travel to Bimini, Bahamas (Bimini). The boats were 2 The parties stipulated that for 1983 Nelson Locksmith paid petitioner and Emmens $1,500 per month, and that they reported $12,301 of rental income on their joint return. We realize that the reported rental income for 1983 is less than $18,000 ($1,500 x 12). The record is silent as to whether petitioner and Emmens received $1,500 each month for 12 months in 1983. Thus, we find that the $5,699 is a concession by respondent in favor of petitioner.Page: Previous 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