T.C. Memo. 2000-22
UNITED STATES TAX COURT
JOSEPH J. HOUSE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
JOSEPH J. HOUSE INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 8664-98, 8665-98. Filed January 19, 2000.
P is a former revenue agent with the Internal
Revenue Service and has been a return preparer for over
28 years. P set up J-Co., a wholly owned corporation,
purportedly to conduct his accounting business. P also
set up C-Co. to hide his assets from the Internal
Revenue Service and X-Co. for his wife’s arts and
crafts business. P conducted his accounting business
at his personal residence. P’s clients hired him
individually to prepare their returns. P was not an
employee of J-Co. and was not acting on J-Co.’s behalf
when servicing clients. J-Co. did not engage in a
substantive business activity. Neither P nor his
family members maintained personal checking accounts.
P deposited all his gross receipts into J-Co.’s account
and paid all his business and personal expenses from
this account without maintaining adequate records to
differentiate between business and personal items. P
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