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petitioner’s wholly owned S corporation, Winston Development,
Inc., overstated deductions on its 1995 Federal income tax return
by $54,802; (6) whether there was an underpayment of tax in 1991;
and (7) whether the underpayments of tax in 1991, 1994, 1995,
1996, and 1997 were due to fraud.
FINDINGS OF FACT
Some of the facts have been stipulated and are incorporated
into our findings by this reference.
Petitioner was a resident of Ft. Lauderdale, Florida, when
the petitions were filed.
Petitioner’s Background
Petitioner is a high school graduate. He initially held a
variety of construction jobs before becoming trained to be a
construction project estimator.
In 1968, petitioner started a demolition business that he
operated successfully for 20 years. His business interests grew
to include apartment buildings, a hotel, and a country club. In
1988, petitioner organized Winston Development, Inc. (WDI),3 an
S corporation, to build and sell condominiums in Indiana. At all
relevant times, petitioner owned 100 percent of the stock of WDI.
In the mid-1980s, petitioner also became successfully
3 The parties have stipulated that the name of the
corporation was “Winston Development, Inc.”, though the
corporation filed its tax returns as “Winston Development Corp.”,
and it is frequently referred to in the record by that name.
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