Nancy B. Doyle - Page 7




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               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.                                    






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