- 13 - On March 31, 1992, petitioner was disbarred by the State of New York. Petitioner's $23 Million Life Insurance Policy As suggested in the above-referenced letter that petitioner gave to some of his clients, in the fall of 1990, petitioner applied for a $23 million life insurance policy with Metropolitan Life Insurance Co., which policy was approved on December 28, 1990. On January 18, 1991, the policy was canceled because petitioner's check in payment of the January $7,363 premium was not honored. Petitioner’s Federal Income Tax Returns And Respondent’s Audit As of December of 1990, petitioner had not filed his Federal income tax returns for the prior 15 years. In early December of 1990, respondent's representative contacted petitioner and inquired as to petitioner's failure to file the above tax returns. On January 2, 1991, petitioner untimely filed his individual Federal income tax returns for 1988 and 1989, and on January 3, 1991, petitioner timely filed his individual Federal income tax return for 1990. On his untimely filed Federal income tax returns for 1988 and 1989, and on his Federal income tax return for 1990, petitioner reflected losses from his law practice, no other income, and no tax due. On audit, respondent charged to petitioner as additional income the $7,003,000 that, inPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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