Robert E. Dunham - Page 4

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               Petitioner did not maintain records of his income from his             
          veterinary practice.  Petitioner received payments for his                  
          veterinary services primarily in cash or by check and did not               
          keep records of these payments.  On occasion, petitioner                    
          permitted customers to establish a charge account.  When the                
          customer paid the account, petitioner destroyed records of the              
          account receivable.  Petitioner did not keep records of his                 
          expenses from his veterinary practice, such as the costs of                 
          medical or laboratory equipment, drugs, or medical supplies.  He            
          discarded invoices relating to these expenses.                              
               During the years in issue, petitioner maintained a bank                
          account in connection with his veterinary practice in the name              
          "Crossett Animal Hospital".  Petitioner made deposits to this               
          account totaling $507, $8,462, $43,339 and $87,705, in 1989,                
          1990, 1991, and 1992, respectively.  Petitioner was married and             
          had held his personal residence with his wife as tenants by the             
          entirety under Arkansas law.  In 1987, petitioner transferred his           
          interest in the residence to his wife for consideration of $1.              
               During April 1990, petitioner filed an unsigned Form 1040,             
          U.S. Individual Income Tax Return, for 1989.  On the unsigned               
          1989 return, petitioner reported $30,000 in income from the                 
          premature IRA distribution.  In a letter attached to the return,            
          petitioner stated that he intentionally did not sign the return             
          because signing the return under penalties of perjury, as                   





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