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For convenience, we generally refer herein to the above
Federal income tax returns for 1995 through 1998 relating to
Ahmed and to his wife and to respondent’s notices of deficiency
for 1995 through 1997 relating to Ahmed and to his wife as if the
tax returns were filed by and as if the notices of deficiency
were issued only to Ahmed.
After a difficult and lengthy trial and following the
settlement by the parties of many issues (including agreement for
1997 and 1998 as to the nominee status of various entities Ahmed
controlled and as to the income and expenses of those entities to
be charged to Ahmed individually), the only issues remaining for
decision in these consolidated cases relate to Ahmed’s liability
for 1995, 1996, and 1997 as to the civil fraud penalty and for
1998 as to the fraudulent failure to file penalty and petitioner
K & M La Botica Pharmacy, Inc.’s (K & M), liability for 1995 and
1996 as to the civil fraud penalty.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Many of the facts have been stipulated and are so found.
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