- 7 - On July 28, 1993, Great American Federal checking bank account No. 20374823 (the Great American Federal checking account) was opened in the names of petitioner’s daughters, “Bridget or Meghan Doyle”. Checks were drawn on this account from time to time to pay petitioner and her husband’s expenses.8 The bank statements and canceled checks for this account were mailed to petitioner’s address, where her daughter Meghan Doyle resided. Additionally, checks made payable to the Doyles were deposited into the Great American Federal checking account.9 On July 30, 1993, the Internal Revenue Service filed notices of Federal tax liens against the Doyles for the tax liabilities redetermined by this Court. Between September 18 and September 25, 1993, petitioner and her husband took a vacation to Italy at a cost of approximately $11,000. On September 23, 1993, petitioner’s husband liquidated an investment interest in Colonial Properties, Inc. The proceeds of the liquidation were received in the form of a check in the amount of $20,900 dated September 23, 1993, and made payable to 8Petitioner’s husband explained their use of the daughters’ bank accounts at a bankruptcy creditor’s meeting: “We had our daughter Bridget or Meghan write checks for our living expenses * * *. Quite honestly the reason for this was because we were worried about putting money into our account * * * and take the chance and jeopardizing the IRS attaching that money.” 9On June 10, 1994, petitioner and her husband gave respondent a collection statement which failed to disclose the Great American Federal checking account.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011