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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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