Kenneth Siebert - Page 4

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          because of my schedule."  Petitioner's request was granted, and             
          the return was eventually prepared by petitioner on December 22,            
               D.  Petitioner's Dealings with Margaret Boals                          
               In January 1988, Mr. Franz received a telephone call from              
          his mother, Margaret Boals.  She told him that she had received             
          two notices of deficiency from the IRS demanding a total of                 
          $500,000 in delinquent taxes from her husband's estate.  Mr.                
          Franz contacted petitioner and on April 13, 1988, took him to see           
          Ms. Boals.  During his meeting with Ms. Boals, petitioner                   
          suggested that she withdraw all of her money from her financial             
          accounts and transfer it to him.  Petitioner told Ms. Boals that            
          the IRS could not seize the money if he held it in his trust                
               Ms. Boals agreed to pay petitioner $150 per hour for his               
          services and, over the course of several weeks, gave petitioner             
          three checks totaling $312,436.05 which petitioner deposited into           
          a newly opened trust account.  Petitioner and Ms. Boals agreed              
          that petitioner would use the funds only when Ms. Boals so                  
          authorized.  Between 1988 and 1989, petitioner wrote, with Ms.              
          Boals' authorization, checks on the account totaling $109,124.50.           
          During the same period, however, petitioner also wrote, without             
          authorization, over $180,000 in checks for a variety of his                 
          personal expenses including:  (1) Repairs and parts for his BMW             

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