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including the years in issue. Petitioner was active in the day-
to-day operations of the Bank and had access to all the computer
programs utilized by the Bank. During the years in issue,
petitioner and his former wife, Lois Posnanski, maintained two
personal, interest-bearing bank accounts at the Bank. For each
of the years in issue, petitioner accrued and was paid interest
income on these personal accounts in the following amounts:
Year Amount
1989 $12,334.79
1990 11,116.45
1991 10,999.62
1992 9,320.28
1993 7,493.44
Toward the end of each year in issue, petitioner accessed
the computer programs at the Bank and deleted information that
would cause his interest income to be included on the computer
disk sent to respondent for purposes of reporting interest paid.
Petitioner further caused Forms 1099-INT, Interest Income, not to
be filed with respondent reporting the actual interest income
earned on his personal account and other accounts for each year
in issue. On his tax returns for the years in issue, petitioner
reported the following amounts of interest income:
Year Amount
1989 $785.00
1990 35.00
1991 118.14
1992 31.76
1993 65.62
Petitioner signed tax returns for each of the years in issue with
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