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the Gownis reported a $45,000 loss from this sale on their 1998
return, the IRS adjusted the Gownis’ income to reflect this gain.
2. Corporate Distributions
The Gownis received and deposited into their personal bank
accounts checks from Ava Anthony, net of repayments, totaling
$13,640. The IRS determined that the Gownis should have reported
this amount as dividend income.
The Gownis received and deposited into their personal bank
accounts checks from Tomson, net of repayments, totaling
$101,000. The IRS determined that these distributions were made
from sources other than the proceeds of the transaction between
Tomson and Sembler. Therefore, the IRS determined that the
Gownis should have included this amount in income.
3. Other Income
The Gownis received and deposited into their personal bank
accounts unexplained amounts of cash and checks from sources
other than their business entities or those reported on their
income tax return totaling $80,868. The IRS determined that the
Gownis should have reported this amount on their 1998 return as
income from self-employment.
B. 1999
The IRS made the following determinations with respect to
the Gownis for 1999:
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