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amount of $441,662.05. He knew that each of these checks was
income to him.
In 1987 and 1988 petitioner knew that he had an obligation
to report all of his income on his Federal income tax returns,
whether received by check or cash.
Petitioner knew that he would receive a Form 1099
representing income he received for services rendered to Medicare
and Medicaid patients. He knew that this information would be
sent to the Internal Revenue Service. He also knew that he was
not going to receive Forms 1099 from about 98 percent of the
attorneys who were issuing checks to him for payment of medical
services to their clients.
Petitioner made a copy of each check he received from an
attorney in 1987 and 1988. He would then add the checks each
week and make a notation to himself. He would keep a running
total for the entire year.
Although petitioner claimed that he kept a handwritten list
of the amounts of the various checks he received in 1987 and
1988, he never gave the list to Michael Bruno (Mr. Bruno), his
certified public accountant.
Petitioner usually hand delivered his bill for medical
services on behalf of certain patients to attorney Louis Gerdes
(Mr. Gerdes). This occurred during 1987 and 1988 when petitioner
received 278 and 188 checks, respectively, from Mr. Gerdes.
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