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market account opened by WRP that same month. No other deposits
were made into the money market account. On April 20, 1992,
petitioner closed the money market account and withdrew the
balance ($10,930.58). Petitioner deposited the $10,930.58 into
his personal bank account. Petitioner did not report the
$10,930.58 as income on his 1992 income tax return.
On May 28 and July 24, 1992, Taxman issued checks for $5,000
and $10,000, respectively, to petitioner. Petitioner used these
checks to purchase cashier’s checks payable to a West Fargo law
firm to pay petitioner’s personal 1983 and 1984 income tax
liabilities. Petitioner did not report the $15,000 as income on
his 1992 income tax return.
D. 1993
On February 17, 1993, Taxman paid $310.43 to Schumacher
Goodyear for repairs done in December 1992 to Mary’s car, a 1991
Ford Probe. Petitioner did not report the amount paid for the
repairs as income on his 1993 income tax return.
On October 12, 1993, WFIC issued a check for $7,000 to
petitioner’s sister, Susan Schoeppach. On October 20, 1993, Ms.
Schoeppach wrote a check for $7,000 to Epic Real Estate. The
$7,000 Ms. Schoeppach paid Epic Real Estate was used as a
downpayment on an apartment building that Ms. Schoeppach
purchased. Epic Real Estate brokered Ms. Schoeppach’s purchase
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