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and 1995 taxable years on January 17, 1995, April 17,
1995 and April 15, 1996, respectively.
b. During the 1993, 1994 and 1995 taxable
years, Meri R. Kaufman misappropriated or embezzled
funds from her employer, MIM Corporation in the amounts
of $33,330.47, $57,095.06 and $76,574,76, respectively
as set forth in * * * [exhibits attached to the answer
which list the date, check number, amount, and payee
for each MIM Corporation check representing embezzled
funds].
c. The Petitioner Meri R. Kaufman failed to
accurately report this additional income when she filed
her joint returns for the 1993, 1994 and 1995 taxable
years.
d. The Petitioner Meri R. Kaufman’s failure
to report gross income in the amounts of $33,330.47,
$57,095.06 and $76,574.76 for the 1993, 1994 and 1995
taxable years, respectively, was fraudulent with the
intent to evade taxes.
e. The Petitioner Meri R. Kaufman’s
understatement of gross income resulted in the
understatement of her joint federal income tax
liabilities in the amounts of $6,546.00, $11,577.00 and
$18,226.00 for the 1993, 1994 and 1995 taxable years,
respectively.
f. The Petitioner Meri R. Kaufman’s
understatement of her joint federal income tax
liabilities in the amounts of $6,546.00, $11,577.00 and
$18,226.00 for the 1993, 1994 and 1995 taxable years,
respectively, was fraudulent with the intent to evade
taxes.
g. A part of the underpayment of tax
required to be shown on Petitioner Meri R. Kaufman’s
joint federal income tax returns for each of the
taxable years 1993, 1994 and 1995 is due to fraud with
the intent to evade taxes.
Petitioners failed to file any reply, and on July 30, 1998,
respondent filed a motion, pursuant to Rule 37(c), for entry of
an order that the undenied allegations in the answer be deemed
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