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August 3, 1987. Petitioner did not report the proceeds of check
number 1295 on his 1987 tax return.
On August 28, 1987, the DeKalb County, Alabama Circuit Clerk
issued check number 1883 payable to petitioner in the amount of
$50,000 as a fee earned in connection with the settlement of a
case. On November 10, 1987, check number 1883 was deposited by
Wilson into petitioner’s Personal Account. Petitioner did not
report the proceeds of check number 1883 on his 1987 tax return.
On August 28, 1987, the Alabama Circuit Clerk issued check
number 1886 payable to petitioner in the amount of $278,982 as a
fee earned in connection with the settlement of a case. Wilson
endorsed petitioner’s name to check number 1886 and gave it to
petitioner’s mother. Petitioner did not report the proceeds of
check number 1886 on his 1987 tax return.
During 1987, unexplained deposits of $95,855 were made to
petitioner’s bank accounts and were not reported on his 1987 tax
return. During 1987, petitioner deposited $331,575 into the
Business Account. Petitioner reported gross receipts of $314,424
on his 1987 Schedule C.
1988 Deposits
Respondent determined that during 1988 petitioner made
withdrawals totaling $749,227 by and for the benefit of himself
from Trust Account 1 and Trust Account 2. Respondent also
determined that petitioner redeposited $185,992 of these
withdrawals back into Trust Accounts 1 and 2 during 1988.
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