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accounts or to Diesel Power's Bank of America account were
recorded in the journals. Mr. Giffin did not know about such
payments.
At the time he prepared petitioner's tax returns, Mr.
Giffin was unaware that petitioner had any ownership interest in
Diesel Power. He was similarly unaware that petitioner had an
interest in or affiliation with WHIP or All Patents. He also did
not know that petitioner had signatory authority on any foreign
bank accounts.
Because this information was concealed from Mr. Giffin,
petitioner's 1974 and 1975 income tax returns made several false
statements. Not only did the returns fail to include in income
the interest earned on petitioner's FNCB London and WHIP
accounts, but the returns were not accompanied by a Form 4683
disclosing petitioner's signatory authority over the foreign bank
accounts. Such a form was required to be attached to returns for
years after 1975. When Mr. Dutton, petitioner's subsequent
accountant, filed an amended 1975 return in 1978, still no
disclosure was made of the foreign bank accounts.
On his 1976 income tax return petitioner disclosed the
existence of one FNCB London account on Form 4683, but failed to
disclose the WHIP account. The 1976 foreign bank accounts
disclosure form is also false because it improperly stated that
petitioner's interests in foreign bank accounts was less than
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