Sonne eet TS Ned W STATE OF FLORIDA FILED DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION BOARD OF ACCOUNTANCY 00 JUN-7 PH 2:30 a hoes OF oe _DEpARTMENT OF BUSTESS GRR Petitioner, vs. ‘CASE NO. 97-10750 NICK J. LIGORI, - ; os - 00-290 Respondent. : ADMINISTRATIVE COMPLAINT COMES NOW the Department of Business and Professional Regulation, hereinafter referred to as “Petitioner,” and files this Administrative Complaint before the BOARD OF _ ACCOUNTANCY against NICK J. LIGORI, ‘hereinafter referred to as "Respondent," and alleges: 1. Petitioner is the state agency charged with regulating the practice of certified public accounting, pursuant to Section 20.165, Florida Statutes; Chapter 455, Florida Statutes; " and Chapter 473, Florida Statutes. 2. Respondent is, and has been at all times material hereto, a certified public accountant in the State of Florida, having been issued license number AC 0007766. 3. Respondent’ last known address is 5033 West Laurel Street, Suite 100, Tampa, Aes “Florida 33607. : 4. : “on or about June 29, 1995, Respondent purchased a 1989 Toyota Corolla from Cynthia A Riddle, for the amount of four ‘thousand one hundred ($4,100) dollars. 5. Respondent subsequently created a fraudulent Bill of Sale stating that the as » the fraudulent 6. Respondent intentionally mistépreseritéd the purchase Price of the automobile on Bill of Sale in order to reduce his tax liability, 7. Section 473.323(1 K), Florida Statutes (1995), states that the performance of any fraudulent act while holding a license to practice public accounting shall constitute grounds for which disciplinary actions may be taken. 8. Based upon the foregoing, Respondent is in violation of Section 473.323(1)(k), Florida Statutes, and is therefore subject to disciplinary actions. COUNT 0 9. Petitioner realleges and incorporates the allegations contained in paragraphs 1-5 and 7 above, as if fully stated herein, 10. Respondent forged the signature of Cynthia A. Riddle on the fraudulent Bill of Sale and had the Same notarized by an employee of his certified public accounting firm, Ligori Vailant & Company. 11. Based upon the foregoing, Respondent is in violation of Section 473.323(1)(k), Florida Statutes, and is therefore subject to disciplinary actions. WHEREFORE, Petitioner respectfully Tequests the Board of Accountancy to enter an Order imposing one or more of the following penalties: Tevocation or suspension of Respondent's license, imposition of probation, imposition of an administrative fine and/or any bad e other relief that the Board deems appropriate. y SIGNED this lo" day of ( uvy , 1999, , COUNSEL FOR DEPARTMENT: F | L E D . i lation Charles F. Tunnicliff aed Departrent ot besa Pres Ragu Senior Attorney DEP Florida Bar #0153831 Mh hod, Department of Business and cere tardn Ufa Professional Regulation _o6-\V-T _ Q = Northwood Centre DATE " 1940 N. Monroe St. : Tallahassee, Florida 32399-0792 ~ (850) 487-9629 CFT /mih 3/27/99 PCP: CC/MM/SO 4/27/99

Docket for Case No: 00-002402