Anthony and Gloria Donnora - Page 3

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          (fraud), 6661 (substantial understatement of tax liability), and            
          6663 (fraud) against petitioners as follows:                                
                                      Additions to Tax                                
          Year   Deficiency    Sec. 6653(b)(1)    Sec. 6661    Sec. 6663              
          1988     $9,090          $6,818          $2,273                             
          1989     20,791                                       $15,593               
          1990     31,436                                        23,577               
               Petitioners Anthony and Gloria Donnora, hereinafter                    
          sometimes referred to as Anthony and Gloria, respectively,                  
          invoked this Court’s jurisdiction by filing a timely petition               
          from the notice of deficiency, disputing the entire amounts of              
          the deficiencies and additions to tax.                                      
               2.  Answer                                                             
               Respondent filed an answer to the petition, including                  
          specific allegations with regard to the fraud determinations.  In           
          paragraph 7 of the answer respondent alleges among other things             
          that both Anthony and Gloria (1) failed to deposit substantial              
          amounts of the cash receipts of Forkston Fireworks Mfg. Co.,                
          Inc., hereinafter sometimes referred to as Forkston, into                   
          Forkston’s bank account, (2) used the undeposited cash receipts             
          for personal expenses, and (3) failed to inform their accountant            
          of the undeposited Forkston cash receipts.  Further, in paragraph           
          7 respondent alleges that petitioners’ extensive use of cash and            


               2(...continued)                                                        
          to sections of the Internal Revenue Code of 1986 as in effect for           
          the years in issue.                                                         




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