Jeff A. Wiltzius, Transferee - Page 6

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          handle cash received by House of Babes.  However, he knew about              
          the system House of Babes used to pay shareholders and to keep               
          records.  He was not directly responsible for House of Babes'                
          income tax filings and did not give false and incomplete records             
          to House of Babes' accountant, but he knew that Waldorf and Godby            
          were doing so.                                                               
               4.   Criminal Investigation of House of Babes                           
               Special Agent Brister (Brister) investigated House of Babes             
          and petitioners for tax crimes.  Brister investigated the income             
          tax liabilities of House of Babes from skimmed receipts and the              
          income tax liabilities of House of Babes' shareholders from                  
          constructive dividends for 1984 and 1985.  He interviewed Waldorf            
          on July 24, 1986.                                                            
          C.   Sale of the Assets of House of Babes                                    
               1.   Terms of the Sale                                                  
               On August 14, 1986, the shareholders sold the assets of                 
          House of Babes, i.e., the building, land, fixtures, and                      
          equipment, to 6400 HWY. 17-92, Inc. (the buyer), for $999,103.               
          Norman Kagen (Kagen) was a shareholder of the buyer and was its              
          accountant.  The buyer assumed a $305,814 mortgage, paid $179,387            
          in cash, and gave a $525,000 promissory note bearing 10 percent              
          interest per year (the note).1  The buyer agreed to pay $100,000             

               1These amounts total $1,010,201, although the parties                   
          stipulated that the sale was for $999,103.  This inconsistency               
                                                              (continued...)           




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