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Petitioner received a bachelor’s degree in business
administration from the University of Miami in 1973. Petitioner
holds himself out as a “degreed accountant”. Petitioner was an
Internal Revenue Service agent for less than a year in the late
1970s or early 1980s.
At the beginning of 1994, petitioner was employed by Circus
Circus in Reno, Nevada, as a casino dealer. Petitioner separated
from his wife and moved to Las Vegas, Nevada, by the end of
January 1994. Petitioner was then employed by MGM Grand Hotel,
Inc. (MGM), where he worked as a casino dealer. Petitioner dealt
blackjack and operated roulette, and he was promoted to a casino
table games supervisor by the end of 1994.
Petitioner was also the sole proprietor of two activities
during the year at issue: Beverly Hills Tax Consulting/Levitt
Tax (BHTC) and Beverly Hills Sportscards & Movie Memorabilia
(BHSMM). BHTC and BHSMM shared an office on South Robertson
Boulevard in Beverly Hills, California. BHTC also had an office
in Las Vegas. Petitioner maintained a separate checking account
for each activity. During the tax filing season, petitioner
prepared returns during the day and worked the swing shift at the
casino.
In 1995, petitioner applied for a mortgage with Countrywide
Mortgage Company (Countrywide). Petitioner submitted to
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