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the deal memo was in Marina Del Ray, California. An
“On-Production Loan-Out” was also signed, showing Jigsaw of
Hallandale, Florida, as the lender and petitioner as the debtor,
with an address in Marina Del Ray. The “loan-out” corporation
(i.e., Jigsaw) was used by petitioner, in his own words, as “a
device for getting payroll, so that the money comes, flows into
the corporation, and then it flows back to me as pay, as salary,
and it was just a device for tax planning.” Jigsaw did not
register as a corporation with the State of California.
In June 1996, petitioner was living on a friend’s boat in
Marina Del Ray. He then moved into a friend’s mother’s apartment
in California. In October 1997, he moved to Hillcrest Road in
Los Angeles.
Notice of Federal Tax Lien
Assessments were made against petitioner for Federal income
tax for 1990, 1991, 1992, 1993, and 1994. The validity of the
original assessment of tax for those years is not an issue in
this case. On July 25, 1996, the Internal Revenue Service (IRS)
filed two Forms 668, Notice of Federal Tax Lien, relating to
petitioner’s unpaid tax liability for 1990 in the amount of
$61,864.24 and for 1992, 1993, and 1994 in the amounts of
$4,493.53, $25,115.01, and $22,374.19, respectively. On
September 25, 1996, the IRS filed Form 668 relating to
petitioner’s liability for 1991 in the amount of $62,039.42. All
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