Steven K. Han - Page 31





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          into personal accounts, or took for personal use, additional                
          corporate funds totaling $85,688 in 1988.14                                 
               Petitioner reported no dividend income on his 1988 return              
          from any of his corporations, and the total reported as wages or            
          salary was $37,500.                                                         
          Northwest Audit                                                             
               Northwest commenced an audit of petitioner’s corporations’             
          consolidator activities on March 1, 1988.  Petitioner retained an           
          attorney, Sheldon Belofsky (Belofsky), to represent him and his             
          corporations in the matter of Northwest’s audit of their                    
          consolidator activities.                                                    
               Northwest’s audit of petitioner’s corporations’ consolidator           
          activities revealed large “round number” withdrawals from                   
          corporate accounts going into various brokerage firm accounts.              
          The brokerage account statements were not kept at petitioner’s              
          corporations’ offices, and Northwest had trouble obtaining copies           
          of the statements from petitioner or from the brokerage firms.              
               During the course of Northwest’s audit of petitioner’s                 
          corporations’ consolidator activities, petitioner refused to give           
          Northwest records of receipts from ticket sales to subagents.               
          Petitioner also refused to give Northwest’s auditors personal               

               14 This $85,688 does not form any part of the $986,856 in              
          funds at issue in this case that respondent asserts is taxable              
          income of petitioner in 1988.                                               





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