Ruth E. Neal - Page 9

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          liabilities that would have been due on petitioner’s income had               
          petitioner filed separate Federal income tax returns.                         
               During the years at issue, Alimam did not have any taxes                 
          withheld from his income, and Alimam did not make any estimated               
          tax payments relating to his income.                                          
               In connection with the preparation of petitioner and of                  
          Alimam’s joint Federal income tax return for each of the years                
          1981 through 1996, Alimam would gather the information relevant               
          to the preparation of the tax returns, including the Forms W-2                
          that petitioner provided to him, and take the information to his              
          accountant.  The accountant would prepare the tax returns and                 
          give them to Alimam.  Alimam would sign the tax returns and then              
          generally give the tax returns to petitioner to sign, after which             
          Alimam would take the tax returns back from petitioner and mail               
          to respondent the signed tax returns.                                         
               On their 1993 and 1995 Federal income tax returns, however,              
          Alimam apparently signed petitioner’s signature.                              
               Year after year (from 1981 through 1996) and without                     
          petitioner’s knowledge (and also apparently without his                       
          accountant’s knowledge), in his mailing to respondent of                      
          petitioner and Alimam’s tax returns, Alimam would not include any             
          payment of the tax balances shown to be due on the tax returns as             
          filed, which balances related to unpaid taxes attributable to                 
          Alimam’s income from his medical practice.                                    






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