Donald G. Ford - Page 7

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               have reported a taxable income in the amount of                        
               $94,063.00.                                                            
                    (ag)  Petitioner omitted $31,500.00 in dividend                   
               income from Don Ford Cars, Inc., from his return for                   
               his 1989 tax year with the intent to understate, and                   
               defeat the federal income tax on that income item.                     
                    (ah)  Petitioner omitted $22,917.00 in interest                   
               income received from C. Ball from his return for his                   
               1990 tax year with the intent to understate, evade, and                
               defeat the federal income tax on that income item.                     
                    (ai)  Petitioner omitted $39,874.00 and $22,233.00                
               in interest income from Don Ford Cars, Inc. from his                   
               returns for his 1989 and 1990 tax years, respectively,                 
               with the intent to understate, evade, and defeat the                   
               federal income tax on those amounts.                                   
                    (aj)  Petitioner omitted $55,955.00 and $33,664.00                
               in interest income from Tri-City Credit from his                       
               returns for his 1989 and 1990 tax years, respectively,                 
               with the intent to understate, evade, and defeat the                   
               federal income tax on those amounts.                                   
                    (ak).  Petitioner omitted $7,000.00 in rent income                
               from Don Ford Cars, Inc. from his return for his 1989                  
               tax year with the intent to understate, evade, and                     
               defeat the federal income tax on that amount.                          
                    (al)  In addition to conspiring with Schultz to                   
               evade and defeat income tax for his 1986 through 1990                  
               tax years, Petitioner also gave Schultz information                    
               from which to prepare his returns.  Petitioner with the                
               intent to evade and defeat federal income tax sometimes                
               did not give complete and correct information to                       
               Schultz in order to maximize his fraudulent tax                        
               benefits.                                                              
                    (am)  A part of each deficiency in income tax for                 
               Petitioner’s taxable years 1986 through 1990 is due to                 
               fraud with intent to evade taxes.                                      
               Petitioner filed a reply in which he denied all allegations            
          relating to fraud and alleged that he undertook the transactions            
          described in respondent’s reply in good faith and relied on                 





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