- 5 - and take care of their daughter. They purchased $15,000 worth of furniture for their home in 1996. They kept at any given time an average of two to three vehicles, typically leased, which included a BMW 740, a Toyota Four Runner, a Porsche, and a Honda NSX. They also owned a jet ski. The family generally ate out several times per week and took vacations, particularly ski vacations, two to three times per year. Both spouses bought expensive clothing and owned watches and jewelry which were kept in bank safe deposit boxes. Petitioner primarily used a credit card for his purchases and then gave the receipts to Mrs. Ishizaki. Bill payment and family finances were then handled by Mrs. Ishizaki. The couple also maintained a joint checking account. On February 6, 1997, respondent commenced an examination of Privilege House. The taxable year under consideration was 1995, and the examination was begun on the basis of two checks obtained by the Internal Revenue Service from a check-cashing business. Revenue Agent Mayra Encarnacion performed the examination and in connection therewith conducted an interview on June 2, 1997, with Mrs. Ishizaki and Jane Kim, the accountant for Privilege House and for the Ishizakis personally. Ms. Encarnacion asked at the interview whether all corporate checks were deposited to the Privilege House account and was initially told that they were. Subsequently, however, when Ms. Encarnacion raised thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011