Fraud Concession Forfeits Argument Against Late Tax Notices

A California franchisee who’d pleaded guilty to tax evasion conceded enough proof of fraud that state-issued notices of tax deficiency could be levied after the typical statute of limitations, a state tax tribunal said.

A three-judge panel of the California Office of Tax Appeals said that the state acted properly in issuing three notices of deficiency against Ajay Beri Corp., a franchise Subway restaurant locations, for the years 2003 to 2010. California Department of Tax and Fee Administration made the notices after a legal case against the company’s president, A. Beri, who admitted to felony tax evasion as part of ...