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During 1982 and 1983, petitioner was married to Crucita
Cannon. Crucita Cannon worked with petitioner at SAIC.
Petitioner also had a secretary named Judy Sanchez.
Hanibal “Mike” Justo (Justo) and his wife, Graciela Justo
(the Justos), were bilingual (English and Spanish) and ran a
small income tax service and wedding chapel in Santa Ana. The
Justos referred some cases to petitioner and assisted petitioner
in dealing with Hispanic clients.
Petitioner and the other persons working in his office
maintained 22 receipt books in which they recorded payments
received from and balances due from clients of SAIC. The
payments included fees earned by petitioner as well as
reimbursements for filing fees and payments for services rendered
by persons other than petitioner.
The money receipt books reflected total payments of
$339,866.54 received during 1982 and $130,710 received during
1983. Petitioner also received fees of $500 from Octovio Molina
and $2,000 from Gerald Scott during 1982 that he did not record
in the money receipt books.
Early in 1983, petitioner’s sister, Sharon Cannon, attempted
to set up books for SAIC for 1982 and 1983. She reviewed the
receipt books, ledger cards, and client files. In 1983, she set
up a client billing system on the computer. She secured from the
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