Linda A. Fields - Page 8




                                        - 8 -                                         
                                        Additions to Tax and Penalty                  
               Year      Deficiency     Sec. 6651(a)(1)     Sec. 6663                 
               1991      $14,505             –-             $129,158                  
               1992      43,026         2,307               299,461                   
               1993      25,376         6,344               19,032                    
          The deficiencies resulted from disallowed deductions for (1)                
          commissions, fees, and contract labor expense consisting of                 
          payments to Mr. Fields’ co-conspirators and certain family                  
          members, and (2) travel and entertainment expenses.  The notice             
          of deficiency also provided that the accuracy-related penalty               
          under section 6662 (for negligence or disregard of rules or                 
          regulations) would apply in the event the fraud penalty did not             
          apply.                                                                      
          Petitioner’s Counsel                                                        
               In August 1999, petitioner’s present counsel, Lawrence                 
          Sherlock, notified petitioner and Mr. Fields (who by that time              
          had divorced) that he could no longer jointly represent them in             
          view of their conflicting interests with regard to the fraud                
          issue, as evidenced by the Appeals officer’s June 2, 1999,                  
          settlement offer.  Petitioner and Mr. Fields agreed that Mr.                
          Sherlock would continue to represent petitioner and that Mr.                
          Fields would retain separate counsel.                                       













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