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Ford station wagon, both of which were financed. Also, petitioners
coowned a beach house in Annapolis, Maryland, which was sold in
1984 or 1985.
Mrs. Taylor handled the family finances. She maintained the
family checking account and paid the household expenses out of the
weekly $500 given to her by petitioner.
Petitioners' three children attended public schools in
Baltimore County and were members of a local swim club.
Occasionally, petitioners went on short family vacations to Ocean
City, Maryland.
Petitioner did not purchase any jewelry, furs, or similar
luxury items for Mrs. Taylor during the years in issue.
Filing of Federal Tax Returns
In January 1992, following petitioner's release from the
halfway house, petitioner and his accountant, Daniel Mules, met
with Revenue Officer Mario Scilipoti to discuss the filing of
delinquent returns for both the grocery/convenience store and
petitioners. Petitioner informed Revenue Officer Scilipoti that he
believed the grocery/convenience store suffered losses during the
years in issue. Petitioner further informed Revenue Officer
Scilipoti that although the records for the grocery/convenience
store were in disarray, he had some documents that he could use for
filing the returns. Petitioner also informed Revenue Officer
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