John Van Heemst - Page 8

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          filed delinquent Federal individual income tax returns, claiming            
          the filing status of married, filing separately.                            
               During the initial stage of the audit for the years in                 
          issue, which began during or about October 1990, petitioner told            
          respondent’s agent that (1) he was merely an employee of Pieces             
          of Eight, (2) the agent was not to ask him any questions about              
          Pieces of Eight, and (3) the agent could not visit its store.               
          Petitioner also represented to respondent’s agent that Pieces of            
          Eight had been owned by Kathleen Murphy, a woman he had never               
          seen.  Petitioner later told respondent’s agent that Kathleen               
          Murphy was an alias used by Ms. Murphy.  Petitioner also claimed            
          that Kathleen Murphy had sold the business to Michael Van Heemst,           
          petitioner’s 17-year-old son, and showed respondent’s agent the             
          asset purchase agreement.  Petitioner admitted to respondent’s              
          agent that none of the sale price had been paid and that he did             
          not know where Kathleen Murphy lived.  Petitioner further claimed           
          during the audit that Pieces of Eight was owned by Michael Van              
          Heemst.                                                                     
               Petitioner initially was unwilling to provide Pieces of                
          Eight’s records to respondent’s agent, but, after the agent                 
          issued a summons, petitioner provided seven boxes of records in             
          April 1991 at Pieces of Eight’s place of business, acting                   
          pursuant to a purported power of attorney given by Michael Van              
          Heemst.  Petitioner, however, did not assist the agent in                   






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