- 3 - Prudential.2 The Prudential clients would write a check made payable to petitioner, and in return the clients would receive an installment note. The installment note stated that it was for an investment known as Neo Genesis Paradigm, Inc.3 Petitioner would then convert the proceeds from this transaction to his own use. Such transactions occurred on three different occasions from 1991 through 1992. Each time, petitioner targeted an elderly client. On May 6, 1992, petitioner was charged in Denver County Court, Denver, Colorado, with theft from the elderly, fraud, and selling securities without a license. Petitioner pleaded guilty to attempted fraud and deceit in offering securities, was placed on probation for 16 years, and was ordered to pay restitution to Prudential in the amount of $107,000. In the notice of deficiency, respondent determined that petitioner did not file returns for the taxable years 1990, 1991, and 1992. Respondent also determined that petitioner realized gross income for those years in the amounts of $20,436, $107,301, and $27,381, respectively.4 The gross income determined by respondent resulted in deficiencies of $2,269, $27,458, and 2In fact, Prudential does not have any connection with Project Input, Inc., nor does the Colorado Secretary of State have a record of it. 3Respondent's first and second requests for admission refer to Neo Genesis Paradigm, Inc. and Neo Genesis. These are references to the same entity. 4Petitioner also did not file individual Federal income tax returns for the tax years 1986-89.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011