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unspecified amount of funds to EPL and that EPL would repay the
funds on demand with interest at a rate of 14 percent per annum.
On petitioner's Federal income tax returns for the years in
issue, the reporting of interest income by petitioner relating to
funds petitioner received from EPL and relating to the alleged
loans petitioner purportedly made to EPL is erratic and
inconsistent. In some years, petitioner received no funds from
EPL, but petitioner reported on his income tax returns interest
income received from EPL. In other years, petitioner reported on
his income tax returns more or less in interest income than the
total funds he received from EPL. In some years, petitioner
reported none of the funds he received from EPL as interest
income. The schedule below indicates, for some years, the
amounts of funds petitioner apparently received from EPL and the
amounts petitioner reported on his respective Federal income tax
returns as interest income received from EPL:
Funds Petitioner Received Funds Reported As
Year From EPL Interest Income
1979 -0- $ 4,965
1984 $ 2,400 6,286
1985 -0- 14,125
1986 52,469 -0-
1987 45,267 3,600
1988 48,454 6,000
On a final decree of divorce between petitioner and his wife
dated January 12, 1987, it is stated that petitioner is awarded
debt owed by EPL to him in the amount of $591,606.
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Last modified: May 25, 2011