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authorization or knowledge of the CEA principals. Bank
statements for account No. 13786145 show a post office box
address in Albertson, New York, that petitioner used for several
of his personal accounts. Two weeks later, on July 14,
petitioner withdrew the $30,000 plus accrued interest. No other
transactions occurred with respect to this account for the rest
of 1986.
Lawrence's check No. 994 for $10,000, dated July 8, 1986,
was deposited directly into one of petitioner's personal accounts
at Fidelity Bank on July 14, 1986.
A Form 1040 that purports to be the joint Federal income tax
return of petitioner and Mrs. Zuckerman for 1986 was filed on
April 16, 1990. Both spouses' names were signed to the return.
The return shows gross income in the amount of $28,160, including
$18,882 of wage income earned by Mrs. Zuckerman, and tax
liability of $199. The funds received from Lawrence were not
reported. A Form 1040 that purports to be the Zuckermans' joint
Federal income tax return for 1987 was received by the Internal
Revenue Service on March 8, 1990. The Form was not signed by
either spouse. It reports gross income of $22,971, including
$21,425 of Mrs. Zuckerman's wage income and Mrs. Zuckerman's
gambling winnings net of gambling losses in the amount of $830.
The Form shows a tax liability for the year of $98.
On audit, Revenue Agent Irwin Dickoff (Dickoff) could not
determine the Zuckermans' income for 1987 from the records made
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