Marcel Toto Ngosso - Page 4

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               During 1996, petitioner was employed part-time by a light              
          fixture store.  He reported $1,774 in wages received from his               
               Petitioner also assisted a tax return preparer, Bakary                 
          Diomande (Mr. Diomande), with the preparation of Federal income             
          tax returns; however, the exact nature and extent of petitioner’s           
          role in the preparation of tax returns is unclear.  Although he             
          testified that he was not a tax return preparer, petitioner also            
          explained at trial that for tax returns that are filed                      
          electronically, “the tax preparer and the taxpayer have to sign             
          that * * *.  And if it’s me who has prepared his taxes, my                  
          signature would appear there.”                                              
               Petitioner testified that he received and cashed checks from           
          Mr. Diomande’s clients, which he then paid over to Mr. Diamonde,            
          because Mr. Diomande did not accept checks as payment from his              
          clients.  The record contains a money order and numerous checks             
          made payable to petitioner or a third party that petitioner                 
          either cashed or deposited into his Chevy Chase Bank account.               
          For example, petitioner’s Chevy Chase Bank account statements               
          reflect that petitioner cashed in part and deposited in part a              
          U.S. Treasury refund check issued in 1996 to Somia Essomba Toto             
          Ngosso, and deposited a U.S. Treasury refund check issued in 1996           

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