Mahendra K. Tandon - Page 7

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          year.  On or about March 9, 1989, petitioner filed an amended               
          return for 1987 reporting an additional $56,000 of income.  On or           
          about May 12, 1989, after Guru Prasad Tandon (petitioner's                  
          father) had died, Forms 1040EZ (the Forms 1040EZ) were filed for            
          1985, 1986, and 1987 in the name of Guru Prasad Tandon to report            
          the rental income from the rental property.                                 
               Petitioner told Ms. Lippert that he deposited all of his               
          medical practice receipts into one checking account at AmeriTrust           
          and that he lost all of his records for 1985 in a flood.                    
               In late 1989, the Examination Division referred petitioner's           
          case to the Criminal Investigation Division.  In November of                
          1989, Special Agent Daniel Dever (Mr. Dever) began a criminal               
          investigation of petitioner.  Shortly thereafter, an amended 1988           
          corporate tax return for Superior, reporting additional income,             
          was filed.  Petitioner told Mr. Dever that he reported all items            
          deposited into his bank accounts on his tax returns.  Petitioner            
          later admitted to Mr. Dever that he did not report some medical             
          service income from AARP and the Ohio Industrial Commission and             
          Bureau of Workers' Compensation on his tax returns.                         
               Mr. Dever served summonses on various banks for signature              
          cards, bank statements, deposit tickets, support items for the              
          deposit tickets, and canceled checks.  Mr. Dever contacted all              
          third-party payors regarding checks deposited into the summonsed            
          bank accounts and confirmed whether their checks were paid to               
          petitioner for medical services rendered.  Mr. Dever prepared a             

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