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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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