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filed for D.D. & Associates. On March 21, 1991, before the
criminal trial of Mr. Drummond and Ms. Drummond, a copy of Form
1065, U.S. Partnership Return of Income, for D.D. & Associates
with respect to the taxable year ended June 30, 1984, was pre-
sented to the assistant U.S. attorney and respondent's agent as
having been filed on September 4, 1984. In fact, D.D. & Associ-
ates did not file Form 1065 for that taxable year or for the
taxable year ended June 30, 1985. On April 24, 1995, another
copy of a Form 1065 for D.D. & Associates with respect to the
taxable year ended December 31, 1983, was presented to respon-
dent's agent. In fact, D.D. & Associates did not file Forms 1065
for the taxable years ended December 31, 1983, and December 31,
1984.
On April 24, 1995, during respondent's civil examination of
Mr. Drummond's taxable years 1983 and 1984, Mr. Drummond pre-
sented another inaccurate tax return for 1983 to respondent's
agent. Mr. Drummond has never filed amended returns for 1983 and
1984.
In early 1985, ABC sued Mr. Drummond and Ms. Drummond for
fraud and conversion. However, the suit was not pursued because
Colonel Haller died.
Mr. Drummond was indicted for and convicted under section
7206(1) of willfully subscribing to and filing false returns for
1983 and 1984.
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