William F. Middleton - Page 5




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         seized, including but not limited to, income and expense                     
         journals, bank statements, canceled checks, and other                        
         incriminating evidence.  Petitioner pleaded guilty to the charges            
         on October 13, 1992, and he was sentenced to 3 years of                      
         incarceration, with all but 1 year suspended.                                
               During 1993, the State of Maryland informed the Internal               
         Revenue Service of petitioner’s Medicaid fraud.  During April                
         1994, after he had been indicted and pleaded guilty to Medicaid              
         fraud and obstruction of justice, petitioner, with the assistance            
         of an accountant, filed amended income tax returns for 1989 and              
         1990 and a delinquent 1991 income tax return.  Petitioner, on his            
         amended 1989 return, reported gross receipts of $44,942 from his             
         taxi business, which purported to include the Medicaid payments              
         from the county.  On his amended 1990 return, petitioner reported            
         gross receipts of $145,557 from his taxi business, which                     
         purported to include the Medicaid payments from the county.  Also            
         on his amended 1990 return, petitioner claimed $211,875 in                   
         deductions on a Schedule C.  On his late filed original 1991                 
         income tax return, petitioner reported $263,912 of gross income,             
         which purported to include the Medicaid payments from the county.            
         Also on his original 1991 tax return, petitioner claimed $254,787            
         in taxi business deductions.                                                 
               In addition, petitioner claimed a loss of $ 1,490 from the             
         sale of a taxi.  Petitioner did not sell a taxi during 1991.                 






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