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ledgers of the nominee entities nor on Ahmed’s or the nominee
entities’ Federal income tax returns.
Ahmed caused Saghir to miscategorize as business expenses
certain of Ahmed’s personal expenses that had been paid with
nominee entity funds and caused Saghir to improperly categorize
and record certain intercompany transactions.
After preparing Ahmed’s Federal income tax returns and the
corporate Federal income tax returns for Ahmed’s nominee
entities, Saghir would present the tax returns to Ahmed for
review. After Ahmed reviewed the tax returns, Saghir would make
any changes that Ahmed requested and then deliver the final tax
returns back to Ahmed for signature and filing.
With the filing or submission of the above Federal income
tax returns for 1995, 1996, 1997, and 1998, Ahmed and his nominee
entities generally forwarded to respondent the tax balances
reported due thereon.7
The schedule below summarizes the dates of incorporation of
Ahmed’s nominee entities and the filing (or submission) dates for
Ahmed’s and for the nominee entity Federal income tax returns for
1995, 1996, 1997 and 1998.
7The actual tax payments for which Ahmed, K & M, and Ahmed’s
nominee entities are to be credited are subject to the parties’
Rule 155 computations herein.
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