Angelo F. DeJoy - Page 4

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               For 1988 and subsequent years, the record contains little              
          reliable evidence as to petitioner's tax bases in, and the value            
          of, petitioner’s stock of each of the S corporations.                       
               As of the end of 1987, petitioner apparently had received              
          from Car Stereo and/or the other S corporations $148,574 in the             
          form of a corporate loan.  The evidence is unclear as to whether            
          and, if so, to what extent petitioner ever repaid this purported            
               In the late 1980's or early 1990's, the accountant who                 
          maintained petitioner’s books and records and who was to prepare            
          Federal income tax returns for petitioner personally and for                
          petitioner’s S corporations closed his accounting practice and              
          disappeared.  Many of the financial records relating to                     
          petitioner’s individual Federal income tax liabilities and                  
          relating to petitioner’s S corporations were never recovered from           
          the accountant.  Also, during these years, petitioner experienced           
          significant personal and family problems that interfered with               
          petitioner’s ability to timely file his Federal income tax                  
               Petitioner untimely filed his individual Federal income tax            
          returns for 1989 through 1993.                                              
               On his 1990 individual Federal income tax return, petitioner           
          did not reflect the $8,275 that he paid to the State of New York            
          relating to the outstanding sales tax liability of Car Stereo.              

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