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Affidavit of Terry M. Bennett", which included a listing of
petitioner's outstanding bills and balances due thereon.
Petitioner listed an outstanding mortgage of $865,000. He did
not list any liabilities to the Ben-Jabr family on his support
affidavit.
Petitioner and Linda Bennett entered a permanent stipulation
of divorce with the Superior Court of the State of New Hampshire
on September 16, 1988.
Petitioner's 1988 Federal Income Tax Return
On his 1988 return, petitioner did not attach a Schedule D
or otherwise report any capital gain from the sale of any
automobiles. Petitioner concedes that he failed to report income
for 1988 of $10,000 and $6,500 from the sale of a Bugatti and a
Lotus automobile, respectively. The sale of these automobiles is
unrelated to the five automobiles sold to Mr. Harley on July 8,
1988.
Charles W. Tilton, Jr., is a licensed public accountant in
Hampton, New Hampshire, with over 25 years of experience. Mr.
Tilton prepared petitioner's Federal income tax returns for the
taxable years 1985 through 1988.
On January 25, 1993, petitioner delivered a letter to Mr.
Tilton that petitioner had written for Mr. Tilton's signature
regarding the sale of the automobiles in 1988. The letter, which
petitioner wanted Mr. Tilton to adopt as his own, stated:
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