Edward D. Tonitis - Page 4

                                        - 4 -                                         
          1996        1997        1998      1999                                      
          Wages               $16,665.00  $66,697.00  $60,904.00  $35,398             
          Nonemployee income   22,274.10    6,830.47   15,468.88     --               
          Dividends               253.00        1.00        2.00     --               
          “Funder” fee          2,931.00      --          --         --               
          Rents                   --          --        2,400.00     --               
          S corp. income          --          --       16,867.00   10,349             
          Petitioner received multiple Forms W-2, Wage and Tax Statement,             
          and Forms 1099 from various payers for the years in issue.                  
               Petitioner failed to maintain, or to submit to the Internal            
          Revenue Service (IRS) for examination, complete and adequate                
          books and accounts of his income-producing activities for each of           
          the years in issue as required by the applicable provisions of              
          the Internal Revenue Code and the regulations promulgated                   
          thereunder.  When the IRS requested the records and thereafter              
          issued a summons for them, petitioner sent letters containing               
          frivolous tax-avoidance arguments and filed a motion in a Florida           
          State court to quash the summons.                                           
               In the absence of adequate records, the IRS computed                   
          petitioner’s taxable income for the years in issue by reference             
          to bank deposits, information returns, and information obtained             
          from third-party contacts.                                                  
               Petitioner was the 100-percent shareholder of Colonial                 
          Mortgage Corp. for 1998 and 1999.  Colonial Mortgage Corp. was              
          formed on November 18, 1998, and made an S election on                      
          February 1, 1999, effective November 18, 1998.  Colonial Mortgage           
          Corp. filed corporate income tax returns and the related                    





Page:  Previous  1  2  3  4  5  6  7  Next

Last modified: May 25, 2011