James J. Brookbank - Page 3




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          taxes by putting assets in the names of family members.  The                
          facts pleaded in the answer and supported in many instances by              
          the stipulated facts and evidence are summarized below.                     
                                     Background                                       
               Petitioner resided in Ohio at the time that he filed his               
          petition.  During 1982, 1983, and 1984, petitioner was engaged in           
          the business of selling life insurance.  During those years, he             
          was employed by and received commissions from various life                  
          insurance companies.  Petitioner received total income from these           
          sources of $20,094.50 in 1982, $28,656.12 in 1983, and $47,287.84           
          in 1984.  (The specific amounts paid to petitioner by each                  
          insurance company during each year were set out in detail in the            
          answer, and supporting documents, including canceled checks and             
          commission records, were deemed stipulated.)                                
               During 1983 and 1984, petitioner caused substantial portions           
          of his income to be deposited into a bank account maintained in             
          the name of his mother and his daughter.  Payments out of that              
          bank account were made for petitioner's use.  Petitioner acquired           
          automobiles and caused them to be registered in the name of his             
          daughter.                                                                   
               On or about the due dates for his income tax returns for               
          1982, 1983, and 1984, petitioner prepared Forms 1040 and mailed             
          them to the Cincinnati Service Center of the Internal Revenue               
          Service.  The Forms 1040 included his name, Social Security                 
          number, address, filing status, and claim of one exemption.  The            



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