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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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