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(3) whether petitioner intentionally failed to report income
in an effort to fraudulently evade the payment of taxes; and
(4) whether respondent’s assessment of deficiencies and
penalties is barred by the period of limitations.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, supplemental stipulations of facts, and
the attached exhibits are incorporated herein by this reference.
Petitioner resided in Santa Clara, California, at the time he
filed the petition.
A. General Background
Petitioner has been involved in the trucking business for
more than 20 years. During the years at issue, petitioner was
the sole shareholder, president, and chief executive officer of
Alviso Rock, Inc. (Alviso), a corporation organized and existing
under the laws of the State of California. Alviso was a trucking
and hauling business located in Newark, California.
Additionally, during the aforesaid period, petitioner was the
general manager of George Maciel Trucking, Inc. (GMT), a wholly
owned subsidiary of Alviso. Alviso and GMT were C corporations
that reported their consolidated income on Forms 1120, U.S.
Corporation Income Tax Return, for the taxable years ending
November 20, 1989, 1990, 1991, 1992, and 1993.
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