St. Luc Valbrun - Page 3

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          petitioner had prepared income tax returns,3 but no bank                    
          statements.                                                                 
               From the customer logs provided and various books of                   
          receipt, respondent’s tax examiner (the examiner) computed income           
          from petitioner’s business activities as follows:                           
                              Originally                                              
          Business                   Reported       Per AuditUnderstatement           
          Insurance sales          $7,481         $63,394   $55,913                   
          Tax return preparation        -0-       24,000    24,000                    
          Other services              -0-          2,480        2,480                 
                                   7,481          89,874    82,393                    
               In addition, the examiner also determined that petitioner              
          received interest income from personal loans he made.  The                  
          examiner also verified through Forms 1099 that had been received            
          by respondent that petitioner’s interest income for 1990 was                
          understated.  The examiner verified interest income of $15,414,             
          resulting in an understatement of interest income of $9,179.  The           
          record does not reflect whether any interest from the personal              
          loans was included in this amount.  Therefore, the actual                   
          understatement of interest income could have been larger than               
          $9,179.                                                                     
               On August 4, 1997, petitioner pleaded guilty to one count of           
          willfully making and subscribing a false income tax return under            
          section 7206(1) for 1990.  Petitioner was voluntarily deported              
          from the United States to Haiti as a result of his guilty plea,             


               3Petitioner admitted preparing over 1,500 returns (of which            
          approximately 20 percent were prepared for free), though there              
          were records for only 1,080 returns.                                        



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