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benefits. Aljournia ultimately pleaded guilty to one count of
tax evasion pursuant to section 7201 with respect to taxable
year 1990. Lesely pleaded guilty to one count of tax evasion
pursuant to section 7201 with respect to taxable year 1990, to
one count of gambling from years 1987 through 1994 pursuant to
18 U.S.C. section 1955, and to one count of making false
statements pursuant to 18 U.S.C. section 1920.
Petitioners’ Federal Income Tax Returns
Petitioners employed Ms. Naomi Jenkins (Jenkins), a tax
return preparer who owns an H&R Block franchise in Bayboro,
North Carolina, to prepare their 1987, 1988, 1989, and 1990
Federal income tax returns. For preparation of their 1987 and
1988 Federal income tax returns, Aljournia presented Jenkins
with several boxes of disorganized documents. Jenkins refused
to prepare the returns from the documents presented. Instead,
Jenkins prepared petitioners’ 1987 and 1988 returns using oral
information that petitioners gave her.
For preparation of their 1989 and 1990 Federal income tax
returns, petitioners presented Jenkins with bank statements,
checks, and a paper bag filled with invoices. Jenkins
determined petitioners’ income by reviewing the bank statements,
and she determined petitioners’ expenses by reviewing the checks
and invoices.
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