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false reports of occupancy beginning in late 1992 through mid-
1997. The indictment was filed on June 16, 1998. The 21 related
counts were dropped, including allegations that Lewis falsely
lowered the income amounts for some tenants and indicated that
certain student tenants were not students.
Following an examination of Bentley Court’s tax returns, the
examining revenue agent concluded that Bentley Court had
falsified documents, including changing income amounts and
indicating that certain Bentley Court tenants were not students,
when, in fact, they were. These falsifications were effected to
support Bentley Court’s claim for the qualified tax status
involving low-income housing credits. A review conducted by the
South Carolina State Housing Finance and Development Authority
revealed that 90 percent of the tenants in Bentley Court’s
apartment complex were students. Respondent’s examining agent
concluded that the apartment complex did not qualify because it
did not have qualified tenants, as defined by law. Accordingly,
the low-income housing credits were disallowed for Bentley
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