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offshore account in the Philippines. In 1993, petitioner also
wired $5,000 from Cullen #921 to a bank in Washington State.
B. Nations Bank
Petitioner had a bank account, number 266-216660-1, at
Nations Bank styled “Thomas Lee Woodall, Attorney at Law Trust
Account” (Nations trust account). Petitioner’s Social Security
number was on the Nations trust account.
In June 1993, a $100,000 deposit was made into the Nations
trust account. The $100,000 was wired from offshore into the
Nations trust account. Between June 30 and July 2, 1993,
petitioner wrote 21 checks on the Nations trust account totaling
$99,950--19 checks for $5,000, 1 check for $3,500, and 1 check
for $1,450.
Tax Returns and Notice of Deficiency
Petitioner filed his 1992 Federal income tax return on April
28, 1994. On his 1992 return, the only income petitioner
reported was $38,692 of business income. Attached to the 1992
return was a Form 1099-MISC, Miscellaneous Income, that reported
$38,692 paid to petitioner by Mr. Strong. The 1992 return listed
$0 of tax withheld and $0 of estimated tax payments.
Petitioner did not file Federal income tax returns for 1993
and 1994.
Respondent timely issued a statutory notice of deficiency to
petitioner for 1992, 1993, and 1994. Respondent computed
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