- 6 - B. Dallas Executive Couriers In early 1989, petitioner decided to establish a courier business. To obtain the necessary financing, petitioner persuaded Mr. Franz on March 23, 1989, to sign a letter of credit. A letter for ‹60,000 was issued by the Isle of Man Bank and was secured by the Showwalter pension plan. On April 19, 1989, petitioner incorporated under Texas law Dallas Executive Couriers, Inc. (Executive Couriers). Executive Couriers operated out of petitioner's office at Hercules & Lavery. Hercules & Lavery used, and paid petitioner compensation for, Executive Courier's services during 1989. On October 17, 1990, Executive Couriers forfeited its right to conduct business in Texas, because it failed to pay Texas franchise taxes. Its corporate charter was subsequently revoked on June 17, 1991. III. Respondent's Investigation and Determinations After petitioner was convicted of misappropriating Ms. Boals' money, the Dallas district attorney's office notified the IRS of petitioner's conviction and informed it that petitioner may not have reported the misappropriated funds on his Federal income tax returns. The IRS assigned petitioner's case to Revenue Agent Jesse Luna. Agent Luna obtained court records from the Dallas district attorney's office. Based on these records, Agent Luna determined that petitioner had unreported income of $74,000 and $110,000 in 1988 and 1989, respectively.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011