Estate of Paul Campana - Page 7




                                        - 6 -                                         
               During 1994, petitioner received distributions of $151,272             
          from CNC.  On line 21 of petitioner's return for 1994, she                  
          reported receiving $38,275 of miscellaneous investment income               
          from CNC.                                                                   
               Some time in 1994, after the 1993 return was filed,                    
          petitioner called Mr. Zocks and asked "a general question                   
          relating to when income from an investment should be reported."             
          As part of his preparation of petitioner's 1994 Federal income              
          tax return, Mr. Zocks assembled and mailed to her an "organizer",           
          or questionnaire, based upon information in the previous year's             
          return.  Petitioner listed on the organizer her income from                 
          different sources.  Among the sources of income she disclosed on            
          the organizer for 1994 was "dividend" income from CNC of $38,275            
          that Mr. Zocks later listed on the return as "miscellaneous                 
          investment income" because there was no Form 1099 reporting the             
          distribution.  She provided no other details of the CNC                     
          investment.                                                                 
               Late in 1994, petitioner asked for her invested money back             
          from CNC and was told in December of 1994 that she could get it             
          back "in three months".  CNC became inactive in 1995 when Mr.               
          Cugliari fled to the Cayman Islands.                                        
               Eventually, the activities of CNC and its investors came to            
          the attention of the Internal Revenue Service (IRS).  Petitioner            
          was one of the individuals whose income tax matters were placed             






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