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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
employer.
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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