- 3 -
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
Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011