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agency income of $80,894 and $97,405, and net profit of $41,996
and $45,515, respectively.
3. Miscellaneous Income
In 1985, petitioner sold to Mr. Fry real property located at
1271 Milligan Street, Camarillo, California. Petitioner failed
to report $4,257 of capital gains income from the sale of this
property. Petitioner also received referral fee income from
Attorney William Bogue for referring clients to Mr. Bogue;
neither party introduced evidence as to the amounts of the
referral fees.
In 1985, petitioner acquired 3,000 units in Diamond Shamrock
Offshore Partners Limited Partnership (Diamond Shamrock). In
1985, 1986, and 1987, respectively, Diamond Shamrock distributed
to petitioner $2,800, $8,400, and $8,400.
Also, in 1985, petitioner acquired 3,000 units in Union
Exploration Partners, Ltd. (Union Exploration). Through his
ownership of the Union Exploration stock, petitioner received
distributions of $1,812 and $5,654 in 1985 and 1987,
respectively.
4. Criminal Conviction
On April 7, 1992, a criminal indictment was filed against
petitioner in the U.S. District Court for the Central District of
California. The indictment alleged that petitioner willfully
attempted to evade or defeat his 1985, 1986, and 1987 income
taxes in violation of section 7201, and that petitioner violated
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