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The Federal income tax returns which Ahmed filed for himself
and for his nominee entities generally were filed late, and a
number were filed after respondent’s notices of deficiency were
mailed to Ahmed. Several of the nominee entity Federal income
tax returns were never filed with respondent. Ahmed did not file
his 1998 individual Federal income tax return until after
respondent had determined Ahmed’s liability for the fraudulent
failure to file penalty.
Ahmed took affirmative steps to conceal from respondent his
ownership of various assets. Ahmed repeatedly denied to
respondent’s agent that he owned interests in the corporations
nominally operating the pharmacies, the clinics, and the lab.
Ahmed used other individuals’ names to perpetuate the concealment
of his ownership of the nominee entities.
Ahmed withheld from respondent’s agent information about
Ahmed’s personal and nominee entity bank accounts. After the
issuance of the notices of deficiency, Ahmed, as determined by
the District Court, designed to place assets beyond the reach of
the United States.
Ahmed failed to produce financial records requested by
respondent and actively hindered respondent’s examination. Ahmed
misrepresented facts to respondent’s agent, including the cash
sales generated by the businesses and his relationship to the
nominee entities. Ahmed submitted various sham documents to
respondent’s agent.
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