- 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 incomePage: 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