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promises. Petitioner embezzled funds of the bank and acted with
intent to injure or defraud the bank. Petitioner engaged in
monetary transactions using money he knew was obtained through
criminal activity. Petitioner's 1992, 1993, and 1994 tax returns
were false as to a material matter. Petitioner did not believe
his tax returns for 1992, 1993, and 1994 to be true and correct
as to every material matter and willfully subscribed to the false
returns with the intent to violate the law. Petitioner knew that
the funds he embezzled were not gifts.
Petitioner Rebecca Wright prepared petitioners' Federal
income tax return for 1992. She made no inquiry into whether the
funds received from Mrs. Millyard were taxable income. On their
income tax return for 1992, petitioners reported adjusted gross
income of $67,927.95. For 1992, petitioners' actual adjusted
gross income was $87,727.95. For 1992, petitioners omitted
embezzlement income of $19,800. For the years 1993 and 1994,
petitioners' returns were prepared by Carolyn Witt, C.P.A. On
their 1993 Federal income tax return, petitioners reported
adjusted gross income of $97,984. For 1993, petitioners' actual
adjusted gross income was $267,484. For 1993, petitioners
omitted embezzlement income of $169,500. On their Federal income
tax return for 1994, petitioners reported adjusted gross income
of $97,984. For 1994, petitioners' actual adjusted gross income
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