- 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