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Mr. Zahedi earned a salary of $23,000, and that they had net
losses of $67,560.
During the years in issue, Ms. Entezam and Mr. Zahedi paid
approximately $60,000 for home furnishings, $20,000 for a
swimming pool, and $30,000 for Ms. Entezam’s jewelry. In
addition, they leased two Mercedes-Benz automobiles and took Ms.
Entezam’s parents on vacation to Florida and Nevada.
On January 5, 1994, during the course of an arson
investigation relating to one of the restaurants, U.S. Bureau of
Alcohol, Tobacco, and Firearms agents searched Ms. Entezam and
Mr. Zahedi’s home and seized a handwritten ledger. The gross
receipts reflected on the ledger were substantially larger than
the amounts reported on Ms. Entezam and Mr. Zahedi’s 1989 through
1992 joint tax returns. Respondent used this ledger to compute
the deficiencies relating to the years in issue.
On November 10, 1994, Ms. Entezam and Mr. Zahedi were
indicted and charged, pursuant to section 7206, with filing false
Federal income tax returns relating to 1989 through 1992. Mr.
Zahedi pleaded guilty to all counts in the indictment and served
28 months in Federal prison. Ms. Entezam signed a deferred
prosecution agreement admitting that she willfully filed 1989
through 1992 false joint tax returns in violation of section
7206.
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