Walter Raymond Wilkerson and Susan Gee Wilkerson - Page 3

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          November 2, 1992, and had an extended due date of October 15,               
          1990.  Petitioners did not file income tax returns with the                 
          Commonwealth of Virginia for their 1988 or 1989 tax years.  On              
          May 27, 1992, petitioners provided an unsigned Form 1040 for the            
          1989 taxable year to respondent's revenue agent, who was                    
          examining petitioners' 1988 and 1989 taxable years.  The                    
          information on the unsigned May 27, 1992, and the signed                    
          November 2, 1992, returns was the same.                                     
               Walter R. Wilkerson (petitioner) had been a certified public           
          accountant since 1978, and he practiced, including the                      
          preparation of tax returns, during the years before the Court.              
          During February 1992, petitioner was indicted on 15 counts of               
          scheming to defraud by forgery on U.S. Treasury checks in                   
          violation of 18 U.S.C. sections 2 and 510 and 11 counts of mail             
          fraud in violation of 18 U.S.C. sections 2 and 1341.  Petitioner            
          pleaded guilty to one count of scheming to defraud by forgery on            
          a U.S. Treasury check in violation of 18 U.S.C. sections 2 and              
          510 and on September 30, 1992, was sentenced to serve 15 months             
          in a Federal penitentiary.                                                  
               Petitioner deposited, into a bank account over which he had            
          control, a client's Federal tax refund checks in the amounts of             
          $27,617.17 and $22,759.07 during 1988 and 1989, respectively.               
          Petitioners reported $17,823.47 and $19,817.87, respectively, of            
          the diverted client's refund checks, as though it represented               





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