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income tax returns for BBL. Berson refused, and he was fired as
BBL’s accountant.
Petitioner told Beaudry in 1997 that she did not want BBL to
pay any tax on its income and instructed him and Sherman to
create a scheme whereby BBL could avoid paying taxes on its
income for 1993, 1994, and 1995. Angry that Bussell, Beaudry,
and Sherman had not come up with a workable scheme to underreport
BBL’s income, petitioner took an active and personal role in
discussing and developing alternatives to filing truthful Federal
income tax returns for BBL. She discussed various alternatives
with Beaudry and Sherman, including overstating deductions and/or
generating a false bad investment loss in a subsequent year and
carrying it back to offset the tax liability in prior years. She
ultimately decided to understate BBL’s gross receipts by a total
of $1,201,974 on its returns for 1993, 1994, and 1995, knowing
that this understatement would cause BBL’s income to match the
$1.1 million reported to respondent on Forms 1099 as BBL’s income
for those years.
In October 1997, Rob S. Janpanah (Janpanah) was hired to
prepare BBL’s delinquent Federal income tax returns in lieu of
Berson. Janpanah prepared BBL’s returns for 1993, 1994, and
1995, using accounting records provided by Sherman which differed
materially from those created by Berson. Those returns
underreported BBL’s gross receipts by $600,180, $475,667, and
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