- 18 -18 gambling income. The 1989 return was filed following the execution of search warrants by the Baltimore County Police Department at petitioners' residence, a bank, and one of Mr. Zaban's businesses, in which evidence of illegal gambling and bookmaking activities was seized. In October 1990, Mr. Zaban entered into a closing agreement with the IRS, terminating the 1990 tax year as of March 24, 1990.4 Mr. Zaban agreed to report the net profits from his gambling and bookmaking activities. The 1990 return (signed by both petitioners) reported gross income before adjustments of $289,560 and gambling income of $240,700 (before expenses) on Schedule C in accordance with the closing agreement. Mrs. Zaban provided Messrs. Breschi and Fidati with records and other information necessary to prepare petitioners' returns for 1984 through 1990. She never reviewed their work to determine whether the returns were true and accurate. At times, Mr. Fidati would provide Mrs. Zaban with returns prepared in pencil and would have her sign blank returns. 4 Closing agreements resolve liability issues only for the taxable years covered by the agreements. Sec. 7121; sec. 601.202(a), Statement of Procedural Rules. Thus, the termination of the 1990 tax year on March 24, 1990, conclusively resolved, for purposes of the closing agreement, only the issues for that period. Respondent was permitted to issue notices of deficiency relating to issues and time periods not covered by the agreement.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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