- 6 - other entities with which he was involved. On July 9, 1980, he filed an individual joint return for 1976. Petitioner did not file a Federal income tax return for 1977. No later than 1982, the Internal Revenue Service (IRS) commenced an investigation of petitioner. On April 3, 1986, petitioner pleaded guilty to failure to file his personal income tax return for 1979 in violation of section 7203. On May 19, 1986, he filed individual joint returns for 1978, 1979, and 1980 in order to receive favorable consideration at the time of sentencing on his conviction. In late 1979 or early 1980, attorneys for petitioner employed William Lipton (Lipton), who was then a partner at the accounting firm of Ernst & Whinney, to prepare petitioner's Federal tax returns for 1978, 1979, and 1980. For approximately 3 years, Lipton attempted to reconstruct for petitioner books and records in order to prepare returns. The records, however, were in terrible shape, consisting of nothing but check stubs and canceled checks. Brian Onofrio (Onofrio), an employee of petitioner, also attempted to reconstruct petitioner's records in order to prepare tax returns for the years in issue. Richard Timbie (Timbie) was one of several lawyers representing petitioner in relation to his failure to file returns. Petitioner's return filed for 1976 reported adjusted gross income of $4,315.86. He claimed a loss from the law firm as a subchapter S loss and did not report the income received fromPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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