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State University from the AT #3 account. Petitioner paid his
alimony and child support obligations from the AT #3 account and
the First Federal Savings account. Petitioner used the
Independent Savings Bank account to pay his personal expenses.
Rental Property and Income
In addition to the space in the St. Clair property where
petitioner conducted his medical practice, the St. Clair property
had two residences and garages available to rent (the rental
property). During the years in issue, petitioner rented parts of
the rental property to Robert McMillan, Jeanine Sinclair, James
L. (Leon) and Sharyn Hamm, Ellis Vest, and his secretary Ms.
Alshabani (the renters). The renters paid the following rental
payments to petitioner:
Renter 1985 1986 1987 1988
Martin McMillan $750 $1,050 $1,350 $1,350
Jeanine Sinclair 300 300 300 200
Leon Hamm 313 1,920 1,710 225
Ellis Vest 25 --- --- ---
Total 1,388 3,270 3,360 1,775
The Audit and Criminal Investigation
Prior to September of 1988, the Internal Revenue Service
(IRS) began examining petitioner's 1984, 1985, and 1986 tax
returns. In October or November of 1988, Revenue Agent Maureen
Lippert (Ms. Lippert) took over petitioner's examination. On
March 1, 1989, Ms. Lippert informed petitioner's attorney that
she had expanded the examination to include petitioner's 1987 tax
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