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father’s management of petitioner’s mother’s cleaning service
business. Petitioner did not question his father and would sign,
without careful consideration, documents his father had prepared.
The administrative business services for petitioner’s and
his mother’s businesses were performed in petitioner’s parents’
home, where the books and records were maintained. Petitioner
lived with his parents in that home until sometime during 1994.
When the number of documents necessary for petitioner’s business
became voluminous, petitioner’s father requested a facsimile
stamp of petitioner’s signature for use on business documents.
A business checking account was maintained for K&L
Exteriors. That account was used for payment of petitioner’s
personal and business expenses. During the period under
consideration, petitioner was provided by his father with
approximately $350 a week for living expenses. Petitioner was
aware that K&L Exteriors’ weekly receipts exceeded $350, and he
thought that the excess was being retained and/or used for
operating expenses.
Petitioner’s father also managed the preparation of
petitioner’s individual and business tax returns. Petitioner’s
father retained Doneta Layland, owner-operator of Tax
Consultants, to prepare petitioner’s tax returns. Petitioner’s
father would provide the information necessary to prepare the tax
returns to Ms. Layland. Petitioner had no contact with Ms.
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Last modified: May 25, 2011