- 8 - merely stated that the funds had been disbursed and declined to comment further; (6) When agents of the Internal Revenue Service attempted to contact your solicitors, Maxwell, Glasner & Co., with respect to their involvement in the A.T.O. Marketing Limited settlement, they refused to provide information unless you agreed to waive the attorney- client privilege, which you have refused to do; and (7) Since you directed the disposition of the settlement funds, and were the last person in possession, custody and control of the Bank Draft payable to the Swiss Bank Corporation on May 7, 1987; since you have declined to further document is [sic] disposition, which disposition cannot be documented beyond your receipt; and since the entity for whose benefit it was allegedly applied denies receipt or any benefit from the Bank Draft, it is determined that the entire amount of the Bank Draft is income to you for the taxable year 1987. Accordingly, your taxable income is increased in the amount of $965,425.00 for the taxable year ending December 31, 1987. See the schedule below for this computation. Proceeds from settlement 575,000 pounds sterling Exchange rate 1.6790 dollars to pounds Proceeds from settlement in U.S. dollars $965,425 In the notice of deficiency, respondent also stated (and petitioner does not dispute) that petitioner reported $29,577 in income for 1987. Discussion Petitioner contends that this Court lacks jurisdiction to decide this case because respondent's notice of deficiency is invalid. Petitioner contends that (a) respondent failed to make the required determination of an actual deficiency, (b) the notice was prepared with gross ineptitude, and (c) respondent isPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011