- 15 - for the preparation of his tax returns. Mr. Kelly prepared those spreadsheets using as their basis the deposits and disbursements into, and from, petitioner’s bank accounts. Petitioner did not inform Mr. Brooks that the proceeds from his real estate transactions were deposited into Mr. Miles’s law firm’s trust account, that those proceeds were not accounted for on the spreadsheets, that petitioner used trustees in his transactions, or that petitioner had a Cayman Islands trust account. Petitioner did not give to Mr. Brooks any books, records, or closing statements from his real estate transactions. Petitioner did not file timely his Federal income tax returns for 1977, 1978, 1979, 1980, and 1981. Petitioner did not file his Forms 1040 for those years until June 15, 1983. Respondent audited petitioner for the 1977-1982 tax years, and respondent issued a notice of deficiency for those years on June 13, 1986.12 On September 12, 1986, petitioner filed a petition with the Tax Court (docket No. 36958-86). In January 1988, petitioner and his representative met with respondent’s revenue agent for purposes of resolving that case. Petitioner took an active role in those meetings. Most of the real estate transactions which were at issue for the 1977-1982 tax years 12Petitioner’s representative would not allow petitioner to meet with respondent’s revenue agent assigned to examine his returns or to extend the period of limitations, unless respondent gave petitioner immunity from criminal prosecution.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011