-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 Social
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