- 9 -
1992 returns.9 Petitioner’s accountants were not aware of Newark
T&B until after the Internal Revenue Service (IRS) commenced its
audit and investigation. Alviso/GMT’s bookkeeper was also
unaware of the Newark T&B business operations.
E. Petitioner’s Racing Business
During the years at issue, petitioner maintained an
unincorporated automobile racing business under the name “Alviso
Rock/HK Racing”.10 Petitioner was the sole owner of this
business. During the years at issue, petitioner maintained a
bank account at the Bank of Milpitas, account No. 512-001-102605,
in the name “Alviso Rock/HK Racing”. During the years indicated,
petitioner received the following amounts of racing income, which
he deposited into the aforementioned bank account:
Description 1990 1991 1992
Deposits $16,811.57 $14,397 $31,493.96
Less: nontaxables1 (4,125.34) (4,334) (20,144.00)
Net racing income 12,686.23 10,063 11,349.96
1 The parties stipulated the above nontaxable deposits.
The funds were received from, inter alia, sponsors11 and/or
winnings.
9Petitioner argues that unclaimed expense deductions and
advances/loans substantially offset income that Newark T&B
earned.
10Initially, petitioner characterized this endeavor as an
“operation”, but he admitted at trial that this “operation” was a
business.
11Petitioner’s related businesses, Alviso, GMT, and BAMA,
were among the sponsors.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011