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In an interview with special agents on August 23, 1990,
petitioner stated that the East Gyn Medical Clinic never had a
day where the cash receipts for a single day were more than
$2,000. Petitioner stated that the clinic received very little
cash. On the following day, petitioner asked two employees,
Minnie Malone and Marlene Parsons, to write letters on his behalf
to the IRS stating that the amount of cash received daily at the
clinic ranged from $40 to $800. Both employees refused to write
the letters as proposed by petitioner because the dollar amounts
he asked them to insert were false. During the August 23, 1990,
interview, petitioner told special agents that he believed that
the interest income was not taxable until withdrawn from the
bank. Petitioner then told the agents that his accountant had
told him that the interest was not taxable until withdrawn. When
asked for the accountant's name, petitioner's attorney
interrupted and stated that it was not the accountant but that
Dr. Kalo just heard or knew of it from someone.
Arthur Sweet was petitioner's tax return preparer. Mr.
Sweet was a certified public accountant since 1952. Petitioner
consulted with Mr. Sweet in reference to his tax returns.
Petitioner freely discussed matters with Mr. Sweet. Petitioner
also called Mr. Sweet and inquired how the changes to the tax law
in 1986 would affect him. Petitioner never advised Mr. Sweet
that he had bank accounts in Canada, or in other foreign
countries, other than a bank account in Israel, which was
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