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reflected only a copy of petitioner's signature and did not
reflect a signature of petitioner Janet Wade.
For 1984, petitioner claims a business expense deduction in
the amount of $230,137 with regard to a consulting fee allegedly
paid to Profiteer Corp.
On April 12, 1989, as a result of a criminal tax
investigation with regard to petitioners’ Federal income tax
liabilities for 1982 and 1983, petitioners were charged under
section 7206(1) with filing false Federal income tax returns. On
March 26, 1990, the charges against petitioner Janet Wade were
dismissed. Petitioner, however, pleaded guilty to the charges,
and on June 12, 1990, a judgment was entered against petitioner
for the above offenses.
The parties herein have agreed to the correct amount of
apartment rental income that petitioners should have reported on
their 1982, 1983, and 1984 Federal income tax returns. The
following schedule reflects, for 1982, 1983, and 1984, the rental
income from petitioners' apartment rental business that was
reported on petitioners' joint Federal income tax returns and the
correct rental income as now agreed to by the parties:
Rental Income As Rental Income As
Year Reported Agreed To
1982 $1,000,339 $1,244,386
1983 1,125,890 1,380,080
1984 1,407,818* 1,407,818
* This figure reflects income as reported on petitioners’
purported 1984 joint Federal income tax return.
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