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In November 1988, agents of the Immigration and
Naturalization Service (INS) executed an arrest warrant for
Crucita Cannon and a search warrant for the premises of SAIC.
Crucita Cannon was subsequently convicted of selling fraudulent
immigration documents.
On December 10, 1990, petitioner was disbarred from the
practice of law in California. In its opinion, Cannon v. State
Bar of Cal., 51 Cal. 3d 1103, 1115 (1990), the Supreme Court of
the State of California found that petitioner had committed
“multiple instances of serious misconduct, many of which involved
moral turpitude.”
The statutory notice in this case was prepared based on the
receipt books delivered to the IRS by Nanni. The notice was sent
to petitioner on July 24, 1997. Respondent determined that
petitioner had Schedule C, Profit or Loss From Business, income
from his law practice of $166,001 in 1982 and $73,837 in 1983.
The explanation of adjustments that was attached to the statutory
notice stated:
a. It is determined that Santa Ana Immigration Center
realized income in the amount of $332,002.00 in the tax
year ending December 31, * * * [1982] and $147,674.00
in the tax year ending December 31, 1983. Under the
community property rules of the State of California,
one-half of this income is taxable to you.
Accordingly, your taxable income is increased by
$166,001.00 for 1982 and $73,837.00 in 1983.
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