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1986 and 1987, with respect to either her employment with Abraham
or her other businesses.
B. Joseph and Margaret Abraham
There is no information in the record with respect to any
personal bank accounts maintained by the Abrahams during 1987.
In connection with his law practice and other business or
investment interests, Abraham maintained between 5 and 13 bank
accounts. During the year 1987, checks drawn on an account of
Lawrence's and cashier's checks purchased with funds from one of
her accounts totaling more than $1,200,000 were deposited into
the accounts of Abraham.
For each of at least five of the accounts, Abraham
maintained a general ledger. In connection with his law
practice, he kept various other types of books and records,
including a cash receipts journal and something referred to by
Lawrence as a "daily cash requirements" journal.
III. Respondent's Examinations
The examination of Lawrence's 1986 Federal income tax return
started in February of 1989. Initially it was assigned to
Revenue Agent Frances Thicke. On July 23, 1990, the examination
was transferred to Agent Red. After reviewing the case file,
Agent Red discovered that several bank statements were missing.
He was also concerned that the transactions reflected on the bank
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