- 8 - computerized deposit analysis listing all of the third-party payors who paid petitioner for medical services, the amounts paid, and the bank account the payment was deposited into. Mr. Dever subtracted out of his deposit analysis amounts that were not for medical services. Mr. Dever determined that the amount of petitioner's medical practice income deposited into the various bank accounts was greater than the amount reported on petitioner's 1985, 1986, 1987, and 1988 individual and Superior's 1988 corporate tax returns. Petitioner's Criminal Tax Convictions In United States v. Tandon, 111 F.3d 482 (6th Cir. 1997), the U.S. Court of Appeals for the Sixth Circuit affirmed petitioner's conviction for wilfully filing false individual income tax returns for 1986, 1987, and 1988 in violation of section 7206(1) and for wilfully assisting in the preparation and presentation of a false corporate income tax return for Superior for 1988 in violation of section 7206(2). OPINION Unreported Income Every individual liable for tax is required to maintain books and records sufficient to establish the amount of his or her gross income. Sec. 6001; DiLeo v. Commissioner, 96 T.C. 858, 867 (1991), affd. 959 F.2d 16 (2d Cir. 1992). Where a taxpayer fails to maintain or produce adequate books and records, the Commissioner is authorized to compute the taxpayer's taxablePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011