- 8 - filed delinquent Federal individual income tax returns, claiming the filing status of married, filing separately. During the initial stage of the audit for the years in issue, which began during or about October 1990, petitioner told respondent’s agent that (1) he was merely an employee of Pieces of Eight, (2) the agent was not to ask him any questions about Pieces of Eight, and (3) the agent could not visit its store. Petitioner also represented to respondent’s agent that Pieces of Eight had been owned by Kathleen Murphy, a woman he had never seen. Petitioner later told respondent’s agent that Kathleen Murphy was an alias used by Ms. Murphy. Petitioner also claimed that Kathleen Murphy had sold the business to Michael Van Heemst, petitioner’s 17-year-old son, and showed respondent’s agent the asset purchase agreement. Petitioner admitted to respondent’s agent that none of the sale price had been paid and that he did not know where Kathleen Murphy lived. Petitioner further claimed during the audit that Pieces of Eight was owned by Michael Van Heemst. Petitioner initially was unwilling to provide Pieces of Eight’s records to respondent’s agent, but, after the agent issued a summons, petitioner provided seven boxes of records in April 1991 at Pieces of Eight’s place of business, acting pursuant to a purported power of attorney given by Michael Van Heemst. Petitioner, however, did not assist the agent inPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011