Joseph Alan Piole - Page 22




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          filed a civil suit against petitioner seeking payment.  During              
          1991, petitioner paid $3,952.90 to Spirit Harley Davidson in                
          settlement of the suit.                                                     
          Nontaxable Sources of Income                                                
               During 1987, petitioner received welfare benefits of $3,224.           
          Petitioner did not receive any welfare benefits during 1988,                
          1989, 1990, or 1991.                                                        
               During 1988, 1989, and 1991, petitioner received insurance             
          proceeds in the amounts of $172.28, $1,829.99, and $2,595.10,               
          respectively.  Petitioner did not receive any insurance proceeds            
          during 1987 and 1990.                                                       
          Petitioner's Tax Returns                                                    
          Petitioner used the calendar year for tax reporting and the                 
          cash method of accounting.  Petitioner's Federal income tax                 
          returns for 1987, 1988, 1989, 1990, and 1991 were prepared by               
          paid return preparers.  Petitioner did not keep books and records           
          of his illegal drug sales during the years in issue.  Petitioner            
          did not inform his return preparers of the income that he derived           
          from illegal drug sales, and he failed to report such income on             
          his Federal income tax returns for the years in issue.                      
               The tax return that petitioner filed for 1987 reflects a               
          Schedule C, Profit or Loss From Business, loss of $3,608.85,                
          rental income of $595.50, and taxable income of zero.  The tax              
          return that petitioner filed for 1988 reflects a Schedule C loss            






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