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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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Last modified: May 25, 2011