- 6 - States. On April 21, 1988, petitioner created Blue Lotus Holdings Ltd. (Blue Lotus) in the British Virgin Islands. Trupin paid $1,500 for the formation of Blue Lotus. There was no business purpose for the formation of Blue Lotus. Blue Lotus was subsequently used as an alter ego of petitioner for, among other things, holding title to her residence and for selling artwork and other items at Sotheby’s in New York City, New York. In December 1988, petitioner purchased a Regal 360 Commodore boat, named Black Lotus, for $140,000. Trupin paid $35,000 as a downpayment on the boat. Petitioner financed the balance of the boat, providing false financial information to the lender. The boat was stored in the Virgin Islands. As of December 1988, petitioner owned a Rolls Royce Silver Spur and a 1988 Jeep Wrangler. Between September 5, 1989, and October 24, 1994, petitioner received at least $958,538 from Trupin as proceeds from the disposition of residences and other assets owned by Trupin or corporations controlled by Trupin. IRS Assessments The first letter of proposed deficiency, which allowed Trupin and petitioner an opportunity for administrative review in the Internal Revenue Service (IRS) Office of Appeals, for 1982 and 1983 was mailed on September 5, 1990. The first letter of proposed deficiency, which allowed Trupin and petitioner anPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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