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deposited into Top Play’s accounts, (2) petitioners used cash for
personal expenditures, and (3) there were no specific items of
unreported income.
To compute petitioners’ incomes, Agent Fisher identified
petitioners’ assets, liabilities, and expenses. Agent Fisher
used information obtained from third parties, searches of
petitioners’ residences, and Top Play’s records. For some items,
Agent Fisher used financial statements prepared by petitioners in
1986 and 1987. Agent Fisher determined petitioners’ net worths
as of December 31, 1986 through 1989. (Reference to petitioners’
1986, 1987, 1988, and 1989 net worths are to their respective net
worths on December 31 of the referenced year.) Agent Fisher
reconstructed petitioners’ incomes by comparing changes in their
net worths from one year to the next for the years in issue.
In February 1993, Mr. Del Bosque was arrested for purchasing
anabolic steroids.7 On March 3, 1993, a four-count indictment
was filed in the U.S. District Court for the District of
Minnesota, charging Mr. Del Bosque with conspiring to import, and
to possess with the intent to distribute, controlled substances
(anabolic steroids), and with aiding and abetting the importing,
and possessing with the intent to distribute, controlled
substances (anabolic steroids).
7Mr. Del Bosque competed in body building competitions and
had held two Mr. Minnesota titles. To that end he used anabolic
steroids.
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