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During the years in issue, Mr. Webber exercised
complete and unfettered control over the moneys on deposit
in the above accounts under the name Ghalardi Income Tax
Education Foundation.
Ghalardi filed a return for calendar year 1993 on Form
1041, U.S. Fiduciary Income Tax Return. As part of the
return, there is a Schedule C, Profit or Loss From
Business, which purports to be from a business described
as Consultant/Education that was operated under the name
G.I.T.E.F. The receipts and expenses reported on Schedule
C for this alleged business are as follows:
Gross receipts $22,845
Car and truck expenses $3,415
Rent or lease
Vehicles, machinery & equipment 822
Other business property 7,000
Supplies 5,741
Travel, meals, & entertainment
Travel 534
Utilities 688
Other Expenses
Service charges $990
Freight 19
Team building 113
Bank charges 101
Conventions, seminars 2,391
Dues, publications 943
Parking 10
Samples, displays 89
Contract labor 725
Total other expenses 5,381
Total expenses 23,581
Net profit or (loss) (736)
Respondent made three adjustments in the notice of
deficiency issued to Ghalardi. First, respondent
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