- 15 - income tax returns for BBL. Berson refused, and he was fired as BBL’s accountant. Petitioner told Beaudry in 1997 that she did not want BBL to pay any tax on its income and instructed him and Sherman to create a scheme whereby BBL could avoid paying taxes on its income for 1993, 1994, and 1995. Angry that Bussell, Beaudry, and Sherman had not come up with a workable scheme to underreport BBL’s income, petitioner took an active and personal role in discussing and developing alternatives to filing truthful Federal income tax returns for BBL. She discussed various alternatives with Beaudry and Sherman, including overstating deductions and/or generating a false bad investment loss in a subsequent year and carrying it back to offset the tax liability in prior years. She ultimately decided to understate BBL’s gross receipts by a total of $1,201,974 on its returns for 1993, 1994, and 1995, knowing that this understatement would cause BBL’s income to match the $1.1 million reported to respondent on Forms 1099 as BBL’s income for those years. In October 1997, Rob S. Janpanah (Janpanah) was hired to prepare BBL’s delinquent Federal income tax returns in lieu of Berson. Janpanah prepared BBL’s returns for 1993, 1994, and 1995, using accounting records provided by Sherman which differed materially from those created by Berson. Those returns underreported BBL’s gross receipts by $600,180, $475,667, andPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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