Paul I. Yoshihara, Laura L. Yoshihara, and Krista A. Yoshihara - Page 4




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          the years in issue, petitioners received checks made payable to             
          Landscaping or Paul Yoshihara for landscaping services performed.           
          In 1992, 1993, 1994, and 1995, petitioners received income from             
          landscaping services totaling $175,258, $74,895, $25,995, and               
          $27,290, respectively.  During 1994 and 1995, petitioners                   
          expended a total of $47,300 for food, housing, transportation,              
          clothing, medical expenses, and other personal items.                       
               Although petitioners received income from landscaping                  
          services, petitioners did not file tax returns for 1992, 1993,              
          1994, and 1995.  In addition, petitioners have no documentation             
          substantiating any loans, nontaxable income, gifts, or                      
          inheritances that they may have received during 1992, 1993, 1994,           
          and 1995.                                                                   
               Petitioners assigned all income they earned from 1992                  
          through 1995 to Mountlake.  Mountlake is a nonprofit corporation            
          formed in the State of Washington in 1965.  The only individuals            
          attending Mountlake between 1992 and 1995 were petitioners or               
          their family members.  In addition, petitioners were the only               
          individuals who held signature authority over accounts used by              














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