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following amounts of the loan proceeds in his money market
account or his Atlantic National account: $447,764 from the
Southern Grove I loan; $148,253.74 from the Southern Grove II
loan; $347,646.45 from the Beach Harbor I loan; and $432,689.60
from the River Creek loan.
C. Petitioner’s Federal Income Tax Return for 1985
Brooks, Brooks & David, certified public accountants,
prepared petitioner’s 1985 Form 1040, U.S. Individual Income Tax
Return. Petitioner filed that return on December 4, 1987.
Petitioner reported $75,000 in wages, $14,883 in interest, and
$72,670 in gross rents received. Petitioner did not report the
amounts of the loan proceeds that were deposited in his accounts
in connection with the transactions described in paragraph B,
above. Petitioner reported a loss of $18,558 on Schedule C,
Profit or (Loss) From Business or Profession, and a loss of
$17,670 on Schedule E, Supplemental Income and Loss. Petitioner
reported adjusted gross income of $53,625, itemized deductions
totaling $64,703, taxable income of minus $14,198, and no tax
due.
D. Petitioner’s Indictment and Conviction
1. Indictment
In August 1991, petitioner was indicted by a grand jury in
the United States District Court in Jacksonville, Florida.
Petitioner was charged with the following crimes relating to his
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