- 35 - on whether petitioners, for the years ended 1984 through 1986, and Mr. Gherman, for the year ended 1987, omitted from income an amount equal to more than 25 percent of the gross income reported on the returns. We turn now to that issue. Unreported Income Petitioners do not deny that Mr. Gherman embezzled money from FIP's clients between 1982 and 1988, but they nevertheless contend that Mr. Gherman did not receive any unreported income, from any source, before calendar year 1988. Petitioners further contend that Ms. Walters has never received any unreported income. Petitioners maintain that respondent has failed to prove unreported income for the years in issue because, they contend, the schedules prepared for the 1988 bankruptcy, such as the Sweep schedule, the family disbursements schedule, and other schedules that indicate amounts purportedly owned by Ms. Walters and other family members, and on which respondent relies to prove unreported income, are not trustworthy. Petitioners contend further that neither Mr. Gherman nor any Gherman family member benefited from the CD scheme. Petitioners maintain that the Sweep schedule reflects that only $100,000 was payable to a Gherman family member (Ms. Walters). Petitioners contend further that the family disbursements schedule shows that some of the funds reflected on that schedule were used to pay FIP's operating expenses while other funds were paid out as loansPage: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
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