Mike Amini - Page 6




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          internal auditors, and the total amount of unexplained cash                 
          deposits made into bank accounts owned by petitioner and his                
          wife:                                                                       

                    Hospital's Calculation          Unexplained Cash                  
                    of Total Amount          Deposits to Petitioner                   
           Year      Embezzled by Petitioner   and His Wife's Bank Accounts           
          1986           $ 42,105                 $ 63,446                            
          1987           72,727                   56,681                              
          1988           105,968                  86,383                              
          1989           157,396                  138,294                             
          1990           228,890                  203,133                             
          1991            193,187                        120,846                      
          Total          $800,273                 $668,783                            

               For the years in issue, petitioner and his wife timely filed           
          joint Federal income tax returns reporting their wages, interest,           
          and dividend income.  For the years in issue, however, petitioner           
          and his wife did not report on their joint Federal income tax               
          returns any of the funds petitioner embezzled from the OPP.                 
               In the notice of deficiency for the years in issue,                    
          utilizing for each year the total of unexplained cash deposits              
          into petitioner and his wife’s bank accounts, respondent                    
          determined that petitioner and his wife received a cumulative               
          total of $668,783 in unreported embezzlement income from the OPP.           
          Respondent also determined that petitioner and his wife were both           
          liable for the fraud additions to tax and penalties and that                
          fraud was attributable to the entire resulting underreporting of            
          income.  Petitioner's wife has filed a separate petition in this            
          Court (docket No. 6978-98) which is awaiting our decision herein.           





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