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(s) On that same date, Petitioner paid $6,000.00
to Schultz for accounting fees.
(t) On that same date, the Bank of Louisville
debited Petitioner’s personal checking account for
$2,036.67 and credited that amount to interest owed on
Schultz’s $800,000.00 note.
(u) On March 20, 1988, Huber’s, Inc., paid in
full the balance on the $300,000.00 promissory note,
plus interest, by a check payable to Schultz in the
amount of $330,969.93.
(v) On that same date Schultz endorsed the
$330,969.93 check for deposit in petitioner’s checking
account.
(w) On October 19, 1987, Petitioner filed his
return for his 1986 tax year. The return included a
Schedule C for "Financing - Sales Notes." The Schedule
C shows gross receipts of $800,000.00, with a related
cost of goods sold of $1,100,000.00, and a loss in the
amount of the $300,000.00 difference. When the loss
was combined with interest income, the net result was a
negative gross income of $187,586.00. And the net
result on Petitioner’s return for his 1986 tax year is
a reported loss for taxable income of $234,345.00, and
a return that is false as to a material fact.
(x) The negative taxable income of $234,586.00
produced carryforward amounts that were carried forward
to Petitioner’s returns for his 1987, 1988, 1989, and
1990 tax years, making each of those returns false as
to a material fact.
(y) As part of his fraudulent actions, Petitioner
willfully failed to report on his return for his 1986
tax year the $800,000.00 in income that he received as
an installment payment on the 1984 sale of the
buildings. If that income had been properly reported
it would have resulted in $739,840.00 in additional
taxable income for Petitioner’s 1986 tax year.
(z) As part of his fraudulent actions, Petitioner
willfully failed to report on his return for his 1988
tax year the $300,000.00 in income that he received as
an installment payment on the 1984 sale of the
buildings. If that income had been properly reported
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