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Petitioner received a total of $280,932 from CNC from November
1991 through January 1995. Respondent does not allege that
petitioner was either a promoter or a salesperson for CNC.
On or about April 15, 1993, petitioner submitted for filing
with the IRS a 1992 Federal income tax return. On that return,
petitioner reported $30,853 in total income, on which he paid
$2,237 in Federal income tax. On petitioner’s 1992 return,
petitioner did not report as income the amount of any CNC check
received by him.
On or about March 7, 1994, petitioner submitted for filing
with the IRS a 1993 Federal income tax return. On that return,
petitioner reported $36,470 in total income, on which he paid
$4,640 in Federal income tax. On petitioner’s 1993 return,
petitioner did not report as income the amount of any CNC check
received by him.
On or about March 28, 1995, petitioner submitted for filing
with the IRS a 1994 Federal income tax return. On that return,
petitioner reported $44,601 in total income, on which he paid
$7,884 in Federal income tax. On petitioner’s 1994 return,
petitioner did not report as income the amount of any CNC check
received by him.
Subsequent to the filing of petitioner’s aforementioned
Federal income tax returns for 1992, 1993, and 1994, petitioner
submitted for filing with the IRS amended tax returns for the
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