A. Lee Petersen and INI Builders, Inc. - Page 18

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          Settlement Between Petitioner and Burke’s Estate                            
               Early in 1988, respondent became aware of the inconsistency            
          between the estate’s and INI’s treatment of the payments that INI           
          had made to the estate.  The IRS contacted Thorpe regarding the             
          estate’s failure to file Federal income tax returns for the                 
          $100,000 “bonus” from INI.  Scanlon-Hull had never seen a Form              
          1099 for any of the bonus payments.  Petitioner had previously              
          told Thorpe that the taxable estate was going to be less than               
          $300,000, so that a Form 706 would not be required.  Thorpe told            
          petitioner that the IRS was asking Burke's estate to file an                
          income tax return reporting $100,000 of income from INI.  In a              
          letter dated February 25, 1988, petitioner urged Thorpe not to              
          file any tax returns until petitioner had had the opportunity to            
          review and discuss them with him to ensure consistency with INI's           
          treatment of the payments.                                                  
               Around February 1988, Thorpe retained Laurel Peterson                  
          (Peterson) and Rodney Kleedehn (Kleedehn) as new counsel for                
          Burke’s estate.  In May 1988, petitioner met with Peterson,                 
          Kleedehn, and Scanlon-Hull to discuss a settlement between                  
          petitioner and the estate.  During the settlement negotiations,             
          petitioner urged Thorpe to file an income tax return for the                
          estate declaring bonus income from INI.  Petitioner offered to              
          pay the estate's income tax liability attributable to reporting             
          the payment received from INI as a bonus.  Thorpe and the estate            





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