Paul L. Tregre, Jr. - Page 9

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          Car and truck                                                               
          expenses            --        --        1,781.60    9,901.00                
          Insurance           --        --        800.00         --                   
          Total          6,772.16    5,823.94   8,955.28   10,961.00                  


          Additionally, petitioner claimed an investment tax credit in the            
          amount of $821 for the purchase of a Corvette automobile in 1982.           
          Petitioner claimed similar expenses against the income he                   
          received from Besco during the period 1974 through 1979.                    
               During the course of Balash's investigation, Tubre and Kahn            
          admitted that they had lied with respect to petitioner’s                    
          involvement in Besco’s sales to customers other than ASI.                   
          Subsequently, Besco pled guilty to one count of violating section           
          7206(1) for filing a return containing a false statement with               
          respect to its payments to petitioner.                                      
               In April 1987, petitioner was indicted on four counts of tax           
          fraud for violating section 7206(1) by taking false deductions              
          with respect to the income received from Besco.  Petitioner was             
          thereafter convicted on each count based on a plea of nolo                  
          contendere.                                                                 
               In April 1992, an internal revenue agent initiated an                  
          examination of petitioner’s tax returns for the taxable years at            
          issue.  Subsequently, respondent determined that petitioner is              
          not entitled to a deduction for the Schedule C expenses claimed             
          for any taxable year at issue.  Respondent further disallowed the           





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