- 4 - For the taxable year 1986, petitioner was involved in the preparation of Federal income tax returns for some of the entities he was involved in. Additionally, a former accountant from Price Waterhouse worked full time in petitioner’s office handling some of the returns. Peat, Marwick, Mitchell & Co., C.P.A.s (Peat Marwick) prepared partnership tax returns for Bilzerian & Mack, Bilzerian Investors and Bilzerian Ventures. Another accountant and a tax attorney were involved in preparing tax returns for other entities which petitioner was involved in. While Peat Marwick was not engaged by petitioner to prepare or do any work on the 1986 individual income tax return, Peat Marwick did prepare a schedule, entitled “Paul Bilzerian’s 1986 Tax Estimate”. This schedule was prepared for the purpose of helping petitioner make an estimated tax payment for 1986. The schedule reported the following gains from petitioner’s stock dealings in Hammermill: Item Amount Bilzerian & Mack $1,840,003 Bilzerian Investors 10,216,579 Bilzerian Ventures 3,107 Personal Gain 4,170,093 Total 16,229,782 On June 15, 1987, petitioner signed and filed a Form 4868, Application for Automatic Extension of Time to File U.S. Individual Income Tax Return, for the taxable year 1986, along with a payment of $5 million. Petitioner was in possession of the schedule prepared by Peat Marwick at that time. On AugustPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011