- 277 - 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 thanPage: Previous 267 268 269 270 271 272 273 274 275 276 277 278 279 280 281 282 283 284 285 286 Next
Last modified: May 25, 2011