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$127,504.82 and made payable to Fidelity National Title,
apparently the escrow agent for the purchase of 7373 Wells
Avenue, and a second cashier’s check was for $47,495.18 and made
payable to petitioner. On June 11, 1990, petitioner deposited
the second cashier’s check for $47,495.18 and the $25,000
cashier’s check purchased with the funds received from Mr.
Viviano into Bank of Milpitas account No. 512-001-300466.
During the years at issue, petitioner conducted an
unincorporated business from the 7373 Wells Avenue location named
Newark Truck and Body (Newark T&B).7 Newark T&B was engaged in
the business of truck repair for petitioner’s related businesses
and for unrelated third parties. Petitioner was the sole owner
of Newark T&B. Newark T&B had its own invoices and business
cards. Newark T&B performed truck repairs work for which it
received remuneration. Petitioner maintained a bank account at
the Bank of Milpitas, account No. 512-001-300466, in the name of
“George A. Maciel c/o Newark Truck & Body”.
Petitioner garnered significant funds from the Newark T&B
activity.8 Petitioner did not report any of the moneys that
Newark T&B received for repair services on his 1990, 1991, or
7Petitioner initially characterized Newark T&B as an
“activity”. At trial, petitioner admitted this “activity” was a
business.
8On brief, petitioner concedes that total deposits
attributable to Newark T&B for the 3-year period were
$123,953.77.
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