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issue, petitioner did not file Federal income tax returns. At
the time the petition was filed, petitioner resided in Runnells,
Iowa.
During the years at issue, petitioner worked as a business
consultant. For a number of years during this period, petitioner
was paid by Larryann Hunt, Inc. for rendering consulting ser-
vices. The services provided to Larryann Hunt, Inc., primarily
consisted of bookkeeping functions. It is not clear how many
other clients petitioner worked for during these years, and
petitioner has not provided any documentary evidence relating to
the amount of consulting income that he earned from 1987 through
1993.
Petitioner is a general partner in Cedar Grove Limited
Partnership (Cedar Grove). Petitioner's four children are
limited partners in this partnership.1 Cedar Grove is the record
owner of a farm, and, from 1988 through 1993, this farm was
rented to an individual named Ken Cheers. Petitioner received
rental checks from Ken Cheers and deposited them into various
checking accounts. Petitioner maintained a number of checking
accounts in the name of Cedar Grove. At times, petitioner used
money from the accounts of Cedar Grove to pay his personal living
expenses. It is not clear whether all of the checks petitioner
1It is not clear whether petitioner's wife is a general
partner or a limited partner of Cedar Grove Limited Partnership.
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