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Mr. Ahmed’s business practices, particularly Mr. Ahmed’s
purported dealings in cash and unauthorized use of others’
signatures.
Also in August of 1999, respondent issued notices of
deficiency to Mr. Ahmed and his wife with respect to 1995, 1996,
1997, and 1998. For each year, respondent determined tax
deficiencies based on unreported income and penalties for the
filing of fraudulent returns. The unreported income alleged by
respondent for 1995 largely took the form of constructive
dividends stemming from payment by La Botica of Mr. Ahmed’s
personal expenses, from imputed interest on loans made by Mr.
Ahmed to La Botica, and from retention by Mr. Ahmed of the
proceeds of corporate checks cashed on his behalf at check
cashing services. For 1996 through 1998, the principal ground
underlying the determined deficiencies was unreported cash sales
by various clinics and pharmacies which respondent characterized
as nominee entities or alter egos of Mr. Ahmed.
Following the filing of petitions with this Court in
response to each of the above notices of deficiency, these cases
were initially calendared for trial beginning on October 16,
2000. The cases were later continued, and outstanding discovery
motions, including motions to compel taking of Mr. Darwish’s
deposition, were denied as moot. At present the cases are set
for the Court’s March 19, 2001, trial calendar, and petitioners
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