Steven J. Romer - Page 13

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               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, in                     




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