- 7 - The IRS began an audit of Kolonaki in November 1990. Kolonaki's representative at the January 8, 1991, interview and throughout the audit was David Pryor (Pryor), a C.P.A. with Crisafi, Sciabica and Woodward (Crisafi), Georgiou's regular accounting firm. On March 7, 1991, the IRS began an audit of the year ended September 30, 1989. Early in the JAI audit, Pryor informed the IRS agent that Georgiou was the owner of JAI. In April or May 1991, Georgiou met with Pryor and Robert Woodward, two accountants from the Crisafi firm, to discuss consolidated return treatment for JAI on Kolonaki's September 30, 1990, tax return. Pryor had discovered the beneficial ownership concept in a Bureau of National Affairs, Inc., tax portfolio and presented it to Georgiou. Pryor suggested that a second meeting be held with Georgiou and Lucius P. Bernard (Bernard), Georgiou's attorney, to discuss whether Kolonaki had beneficial ownership of the JAI stock that was issued in Georgiou's name. Georgiou subsequently met with Pryor and Bernard to discuss consolidated return treatment for JAI on Kolonaki's return. Bernard was not a tax specialist. The meeting concluded with the understanding that JAI could file a consolidated return with Kolonaki, if Kolonaki could establish that it was the beneficial owner of at least 80 percent of JAI stock. It was agreed that a Holding Agreement between Kolonaki and Georgiou would be the best way to document the intention that Kolonaki was the beneficial owner of Georgiou's JAI stock.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011