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The defendant stands before this Court as an
apparently intelligent, hard driving business man who
has succeeded in his chosen field. Unfortunately, the
defendant for whatever reason, chose to commit perjury
in the preparation and verification of his tax returns
which means that they were not true and correct as to
every material matter.
2. The Partnerships
Petitioner organized over 100 general and limited
partnerships (the partnerships) for the purpose of acquiring and
developing property for his real estate activities in the
northwest region of Columbus, Ohio. Petitioner was either the
sole general partner or controlled the general partner in each
partnership. DeSantis Associates, for example, was a general
partnership in which DeSantis, Inc., was a general partner, and
petitioner was the managing partner. The stock of DeSantis,
Inc., was owned solely by petitioner. Each partnership had a
separate bank account with BancOhio National Bank (BancOhio) in
Columbus, Ohio. Petitioner also maintained a personal checking
account, No. 830536146, with BancOhio.
Petitioner, as general partner, entered into separate
written contracts with the partnerships in which he agreed to
provide the latter with financial and consulting services.
Specifically, the contracts were entitled "Ongoing Financial and
Tax Analysis, and Investment Counseling Agreements". Petitioner,
as the general partner of the partnerships, signed the agreement
on behalf of the parties. Petitioner agreed to perform the
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