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$5,750 in gross monthly income, amounting to $69,000 annually.
On petitioner's June 4, 1986, application for a loan to purchase
another property, petitioner listed his annual rental income as
$56,880. On the "returns" petitioner attached to the latter
application, petitioner indicated that his receipts from rentals
during 1984 and 1985 were $53,028 and $46,340, respectively; the
amounts listed on petitioner's application and attached "returns"
were significantly greater than the amounts he reported on his
returns which he filed with the Internal Revenue Service.
In 1987, Jimmie and Dorothy Wilson (the Wilsons) occupied
residential real property that they leased from petitioner.
While an audit of petitioner's tax returns was in progress,
petitioner contacted the Wilsons and told them to tell anyone who
asked that they were paying petitioner $275 per month for the
rental of the property. In fact, they were paying $775 per month
for the rental of the property, and they had never made rental
payments as low as $275 per month. Petitioner told the Wilsons
that if they gave false information about the amount of rent they
paid to him to anyone who asked them about it, he would not raise
their rent in the future.
In June 1987, Revenue Agent Paula Lurvey (Agent Lurvey)
contacted the Wilsons and inquired about the amount of rent they
paid to petitioner. The Wilsons told Agent Lurvey that they paid
petitioner $275 per month. In August 1990, special agents of the
Criminal Investigation Division of the Internal Revenue Service
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