-3- Unless otherwise indicated, section references are to the Internal Revenue Code. Unless otherwise indicated, Rule references are to the Tax Court Rules of Practice and Procedure. I. FINDINGS OF FACT Some of the facts have been stipulated and are so found. A. Petitioner Petitioner lived in Las Vegas, Nevada, when he filed his petition. Petitioner was a certified public accountant from 1964 through the year at issue. In 1984, he operated a bookkeeping business, A.C. Bingham & Associates, C.P.A. Petitioner had a bank account for A.C. Bingham & Associates at Valley Bank of Nevada (Valley Bank) in 1984. B. Petitioner's Handling of the Lopps' Land Sale Proceeds Two of petitioner's clients were Eva and Odell Lopp (the Lopps). Petitioner was Mr. Lopp's trustee for a land sale in Laughlin, Nevada, in 1984. Petitioner received a $676,720.68 check from the Nevada Title Co. as trustee for Mr. Lopp around May 7, 1984. On May 10, 1984, petitioner used the $676,720.68 check to buy time deposit certificates at Valley Bank for $10,000 and $666,720.68. Petitioner bought both time deposits in his name. Petitioner's Social Security number (tax identification number) is 530-26-2319. Petitioner used an incorrect SocialPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011