- 3 -
Year Credit Yearend qualified basis
1990 $28,508 $223,770
1991 699,780 8,372,263
1992 859,543 11,537,221
1993 918,155
1994 926,819
1995 927,606
On its 1990, 1991, and 1992 returns, Bentley Court reported
that it qualified for the credits under the provisions of section
42 but provided no detail about its qualifications for the
credits, including the nature of the building or its tenants.
Respondent did not examine Bentley Court’s 1990, 1991, or 1992
income tax return, and the statutory period for assessment has
expired for those years.
On August 25, 2000, Lewis was sentenced to 30 months in
prison following his guilty plea to 1 of 22 counts of obstructing
and impeding the administration of the internal revenue laws.
The count to which Lewis pleaded guilty was as follows:
Between September 11, 1995, and August 6, 1996, in the
District of South Carolina, EDWIN LEWIS II did
corruptly obstruct and impede and endeavor to obstruct
and impede the due administration of the internal
revenue laws by losing and concealing tenant files for
* * * [two tenants] of Bentley Court Apartments, which
tenant files were to be examined by the Internal
Revenue Service as part of an audit of the partnership
return for Bentley Court II Limited Partnership for
1993;
In violation of Title 26, United States Code,
Section 7212(a) and Title 18, United States Code,
Section 2.
The remaining 21 counts were similar and related to the one
quoted above and concerned allegations that Lewis willfully made
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