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relevant times, if petitioner needed to purchase groceries or
other personal items, Mr. Beatty provided her with the cash or a
check to do so.
At certain relevant times, Mr. Beatty was unable to open
bank accounts or obtain credit in his name because of his poor
credit rating. Instead, Mr. Beatty used petitioner’s name to
open bank accounts, which he used for both personal and business
purposes. Mr. Beatty also obtained credit cards in petitioner’s
name, which he used for business purposes. In addition, Mr.
Beatty used petitioner’s name to finance the purchase of at least
one vehicle that he used for business purposes.
Petitioner and Mr. Beatty did not timely file Federal income
tax returns and State income tax returns for any of their taxable
years 1988 through 1999. On a date not disclosed by the record
in 1999, Mr. Beatty was indicted by the State of Maryland for
willful failure to file a State income tax return (State return)
for each of the taxable years 1995, 1996, and 1997. On May 8,
2000, Mr. Beatty pleaded guilty to failing willfully to file a
State return with the State of Maryland for each of those taxable
years.
On September 8, 2000, as a result of pleading guilty to
failing willfully to file a State return with the State of
Maryland for each of the taxable years 1995, 1996, and 1997, Mr.
Beatty was sentenced to 15 years in prison. That sentence was
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