- 5 - increased dramatically during the years in issue. He concluded that the decedent and Mrs. Spear skimmed cash from the parking lot businesses and used corporate funds for their personal benefit without reporting them as income. Trepple attended the decedent's and Mrs. Spear's criminal trial in December 1982 and January 1983. During that trial, the decedent and Mrs. Spear claimed for the first time that the decedent's father, Abe Spear, had given the decedent $380,000 in cash in 1957. The decedent testified about his father's will, the will contest, and the fact that his father pawned family jewelry and borrowed money, including $1,000 from the decedent's sister, Sadie. C. Notice of Deficiency Respondent issued the notice of deficiency in this case on December 23, 1986. On February 6, 1987, the decedent and Mrs. Spear filed a petition in this Court. Petitioners did not contest respondent's use of the net worth method or respondent's net worth computation, except they contended that they had more opening cash on hand than respondent allowed, and that payments to them from their closely held corporations were nontaxable loan repayments. Petitioners also disputed that they were liable for the addition to tax for fraud.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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