- 29 - account had been transferred during December 1986 from an account with Prudential-Bache in Ms. Walters' name. Justice For All Inc. was a Florida corporation formed by Mr. Gherman to hold funds in brokerage accounts and to hold cash in bank accounts. Tax Returns for the Years in Issue Petitioners filed joint Federal income tax returns for tax years ended 1984, 1985, and 1986. The returns were prepared by or under the supervision of Ronnie Thaw (Mr. Thaw), a certified public accountant (C.P.A.), who had prepared tax returns for petitioners since the 1970's. The joint return for tax year ended 1984 was filed on August 19, 1985. The joint return for tax year ended 1985 was filed on August 15, 1986. The joint return for tax year ended 1986 was filed on September 21, 1987. Mr. Thaw relied on FIP's books and records to prepare petitioners' joint income tax returns for the years ended 1984 through 1986. Petitioners did not engage Mr. Thaw to verify the books or to perform a certified audit, and he did not perform those services. When the joint tax returns were prepared for tax years ended 1984 through 1986, Mr. Thaw was not aware of the CD scheme. Mr. Thaw did not include in income on those joint tax returns any moneys charged on FIP's books and records as loans to either Ms. Walters or Mr. Gherman. After the returns were prepared by their accountant, Mr. Gherman had the returns reviewed by petitioners' tax attorneys before petitioners signedPage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
Last modified: May 25, 2011