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1989 tax years. Respondent received petitioner’s 1990 Federal
income tax return on June 26, 1992.
These documents were all prepared by Harold E. Grierson
(Grierson). Grierson asked petitioner to furnish him with
information and records concerning all of petitioner’s income for
1987, 1988, 1989, and 1990. Petitioner provided Grierson with
filled-out Federal tax forms (prior-year forms with the
preprinted years crossed out), and Grierson copied the amounts
that petitioner had entered on these forms in preparing the
documents. Petitioner did not provide Grierson with any
supporting documentation for the amounts shown on the filled-out
tax forms he gave to Grierson. Grierson did not verify the
figures and computations on the filled-out forms but instead
reviewed them only for internal consistency or placement on the
form.
Petitioner did not sign the documents purporting to be his
1987, 1988, and 1989 individual Federal income tax returns.
Instead, petitioner’s employee, Merle Wilson (Wilson), signed
petitioner’s name on the documents. Wilson routinely handled
banking transactions for petitioner, including the signing of his
checks and the endorsement of his deposits. Wilson had never
signed petitioner’s tax returns before signing the 1987, 1988,
and 1989 tax returns. Petitioner and Wilson did not discuss
Wilson’s signing the documents prior to her doing so, and
petitioner did not authorize Wilson to sign them.
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