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Ahmed in the cumulative total amount of $1,426,038 relating to
Ahmed’s Federal income tax for the same years involved herein
(namely, 1995, 1996, 1997, and 1998).
Ahmed challenged respondent’s above jeopardy assessments in
the Federal District Court for the Central District of
California. In preparation for the court hearing relating to the
jeopardy assessments, Ahmed had a document prepared by his
attorney entitled “Declaration of Ahmad Saghir”. Ahmed offered
Saghir $3,000 and pressured Saghir to sign the declaration.
Although Saghir felt threatened by Ahmed, Saghir did not sign the
declaration because it contained false statements.
On August 18, 1999, the District Court sustained
respondent’s above jeopardy assessments on the ground that Ahmed
appeared to be designing to place property and assets beyond the
reach of the United States.
Stipulation as to Income and Expenses
As to 1995, 1996, 1997, and 1998, the parties have
stipulated to the income and to the allowance or disallowance of
all of the expenses claimed on Ahmed’s and on the nominee entity
Federal income tax returns as filed.
Also, as indicated, as to 1997 and 1998, the parties have
stipulated to the collapsed treatment of Ahmed’s nominee
entities, i.e., that the stipulated income and the stipulated
allowable expenses of the nominee entities are to be charged to
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