Joan Walters, f.k.a. Joan Gherman, and Henry Gherman - Page 9

                                        - 9 -                                         

          $1,078,177.  Additions to tax for fraud were determined in the              
          related notices of deficiency and affirmatively pleaded in the              
          answers to the petitions for taxable periods ended 1973 through             
          1979.  By agreement of the parties, decisions were entered                  
          wherein deficiencies in tax for taxable periods ended 1975                  
          through 1981, aggregating $164,626, were sustained, but additions           
          to tax for fraud were not sustained for any taxable period at               
          issue.                                                                      
               In the notices of deficiency sent to FIP for years ended               
          1975 through 1981, respondent disallowed as unreasonable                    
          compensation deductions claimed for moneys FIP paid to Ms.                  
          Walters on the basis that Ms. Walters "performed no more than               
          nominal services" for FIP.  In those notices of deficiency                  
          respondent also disallowed as unreasonable a portion of the                 
          compensation FIP paid to Mr. Gherman.  During 1984, Ms. Walters             
          asked Mr. Gherman to remove her from FIP's payroll, because she             
          wanted to avoid future problems with the IRS.                               
               Another issue in those Tax Court cases related to activities           
          in marketing tax shelters (film and art) to FIP's clients.   Ms.            
          Walters participated to some degree in setting up or putting                
          together at least one tax shelter, but the record does not show             
          the extent of that participation.  Respondent also disallowed               
          some business expenses claimed by FIP in the notices of                     
          deficiency for years ended 1973 through 1981.  Unreported income            





Page:  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