Monty Bisceglia and Patricia Bisceglia - Page 5




                                        - 5 -                                         
               During 1992 and 1993, petitioner and Jack operated a body              
          shop on property located at Netherland Inn Road in Kingsport,               
          Tennessee.  The body shop purchased wrecked autos which it would            
          repair and resell through Murphy’s.                                         
               During the years in issue, petitioner and Jack also built              
          and sold condominiums.                                                      
               On May 3, 1995, petitioner signed and gave a "Personal                 
          Financial Statement" to NationsBank representing as "true and               
          complete" that he had a salary of $144,000 and a net worth of               
          $1,321,650.                                                                 
               Petitioners’ returns were prepared by an old school friend             
          of Jack’s who was an accountant in Florida.  To prepare the tax             
          returns, the accountant used information from a one-page summary            
          that Jack supplied.                                                         
               On their 1993, 1994, and 1995 returns, petitioners reported            
          adjusted gross income (loss) of ($11,652), $16,270, and $18,635,            
          respectively.  Petitioners’ returns indicate that Murphy’s was on           
          a cash basis for 1993 and 1994 but on an accrual basis for 1995.            
               Respondent’s examination of petitioners’ 1993, 1994, and               
          1995 returns began in May 1996.  Following an initial examination           
          of petitioners’ books, respondent’s agent reconstructed                     
          petitioners’ income using the net worth method.  To that end,               
          respondent’s agent identified petitioners’ assets, liabilities,             
          and expenses.  Respondent’s agent then reconstructed petitioners’           






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Last modified: May 25, 2011