K & M La Botica Pharmacy, Incorporated, et al. - Page 28

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               Ahmed denied having any connection to Macca, and Ahmed                 
          provided inconsistent information to respondent’s agent about the           
          sources of funds used to purchase properties held in Macca’s                
          name.                                                                       
               Although Ahmed controlled and had signatory authority over             
          numerous personal bank accounts and bank accounts of the nominee            
          entities, Ahmed did not cooperate in producing to respondent’s              
          examining agent the bank records relating to the operation of the           
          pharmacies, the clinics, and the lab.  Also, Ahmed instructed               
          Saghir not to cooperate in turning over bank records and other              
          records to respondent’s examining agent.  Further, Ahmed failed             
          to acknowledge all of the bank accounts that he and his nominee             
          entities maintained or utilized.                                            
               Ahmed prepared or caused to be prepared and provided to                
          respondent a variety of false documents, such as minutes of                 
          nonexistent corporate meetings and sham sales documents.                    

          Notices of Deficiency                                                       
               After respondent’s audit of Ahmed’s 1995, 1996, and 1997               
          individual Federal income tax returns and of K & M’s 1995 and               
          1996 corporate Federal income tax returns, and after the                    
          preparation by respondent of a substitute tax return for Ahmed              
          for 1998, respondent determined the above Federal income tax                
          deficiencies against Ahmed for 1995, 1996, 1997, and 1998 and               
          against K & M for 1995 and 1996.                                            





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