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services; or the checks were payable in amounts petitioner
normally charged for office visits--so he included these payments
in the schedules.
Respondent determined that petitioner underreported his
gross receipts by the following amounts deposited, in the form of
checks from patients and cash, into his three bank accounts:
Petitioner's
Year APSB Acct. #1 APSB Acct. #2 SPB Acct. Total
1988 $34,082 $415 $15,795 $50,292
1989 37,037 --- 21,934 58,971
1990 53,577 --- 13,911 67,488
Dr. Beauchamp's Real Estate Activity
Ms. Choe was the owner of the following real property (Ms.
Choe's properties):
15149 Mission Hills Road, Mission Hills, Cal.
14850 Ryan Street, Sylmar, Cal.
14708 and 14714 Chatsworth Street, Mission Hills, Cal.
14640 Brand Boulevard, Mission Hills, Cal.
11031 and 11038 Burnet Avenue, Mission Hills, Cal.
11065 Arleta Avenue, Mission Hills, Cal.
Petitioner paid the mortgages on Ms. Choe's properties.
Prior to 1988, petitioner entered into an oral agreement
with Ms. Choe pertaining to real estate related activities.
Under the agreement, petitioner supervised the improvement of Ms.
Choe's properties (including the demolition of existing
structures and the construction of two family residences).5 In
5 Petitioner was not a licensed contractor in the State of
California, but he had a lifelong interest in "tinkering" with
(continued...)
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