before the california board of accountancy … · steven made pybrum (1'espondent)...

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BEFORE THE CALIFORNIA BOARD OF ACCOUNTANCY DEPARTMENT OF CONSUMER AFFAIRS

STATE OF CALIFORNIA

. In the Matter of the Accusation Against:

STEVEN MARK PYBRUM

Certified Public Accountant Certificate No. 31088,

PYBRUM & COMPANY, LLP

Certified Public Accountant Partnership Certificate No. 7514,

Res ondents.

Case No. AC-2013-36

OAH No. 2015060269

DECISION

The attached Proposed Decision of the Administrative Law Judge is hereby accepted and adopted by the California Board of Accountancy as the Decision in the above-entitled matter.

This Decision shall become effective 1-z,\ ·1 <1:5' \) ((> --~~--~---------------

Prelol9a4 California Board of Accountancy

BEFORE THE CALIFORNIA BOARD OF ACCOUNTANCY DEPARTMENT OF CONSUMER AFFAIRS

STATE OF CALIFORNIA

In the Matter of the Accusation:

STEVEN MARK PYBRUM OAH No. 2015060269


Respondent.

PYBRUM & COMPANY, LLP,

Certified Public Accountant Partnership Certificate No~ 7514,

Steven Pybrum, Jenna Salcedo, Partners,

Affiliated License.

PROPOSED DECISION

This matter was heard by Humberto Flores, Administrative Law Judge from the Office of Administrative Hearings, on September 6, 2016, in Los Angeles, Califomia.

Matthew A King, Deputy Attomey Genei'al, represented the complainant.

Steven Made Pybrum (1'espondent) appea1'ed pe1'sonally and was 1'epresented by Scott J. Harris, Attomey at Law.

Evidence was received and the 1'ec01'd was left open to allow complainant and i'espondent to submit certain documents, including cui'tent certifications of licensure from complainant's tecotds and certified copies of respondent's tax returns (tax yeai'S 1994-1996) identified and admitted as Exhibits H, I and J. On September 9, 2016, complainant submitted current certifications of license history for respondent's certificate and the affiliated license issued to Pybrum & Company, LLP. These certifications wei'e marked, admitted and included as part of Exhibits 2 and 3.

On September 12, 2016, Mr. Harris submitted a letter stating that respondent was not able to obtain certified copies of his individual tax returns filed in 1994 through 1996, because "they were beyond the document retention period of the [IRS]." The letter was marked Exhibit K for identification only. The record was closed and the matter was submitted for decision on September 12, 2016. The Administrative Law Judge finds as follows:

FACTUAL FINDINGS

1. Complainant Patti Bowers made and filed the Accusation in her official capacity as Executive Officer of the California Board of Accountancy, Department of Consumer Affairs (Board).

·2. On December 5, 1980, the Board issued certified Public Accountant Certificate (CPA) No. 31088 to respondent. The certificate was renewed on AprilS, 2015 and is in effect through March 31, 2017.

3. On October 23, 2012, the Board issued CPA Partnership Certificate No. 7514 to Pybrum & Company, LLP, with respondent and Jenna Salcedo, a non-licensee, as partner. The certificate became effective two days before respondent suffered the conviction set forth in Factual Finding 4, and eight years after respondent engaged in the conduct underlying his conviction. The certificate has been renewed through October 31, 2016. On March 30, 2016, Jenna Salcedo was disassociated as a partner. As a result, Pybrum & Company, LLP, no longer complies with Business and Professions Code section 5072.

4. On October 25, 2012, in the United States District Court, Central District of California, respondent was convicted by ·a jury of four felony counts charging violations of 26 United States Code Section 7206(1), willfully maldng and subscribing to false federal income tax returns. On March 4, 2013, the court sentenced respondent to 36 months in prison. After completing his prison term, respondent was placed on and is currently serving his term of supervised release. Respondent appealed his conviction to the United States Coutt of Appeal for the Ninth Circuit. The Court ofAppeal affirmed respondent's conviction on July 17,2014.

5. The facts and circumstances underlying the conviction were that respondent filed false individual income tax returns from 1999 through 2002. Respondent underreported individual income during these four years as part of a sophisticated scheme to avoid paying taxes on money he earned from accounting services. In 1998, respondent incorporated the "Foundation for Harmony and Happiness" (Foundation) as a 50l(c)(3) charitable organization with the stated purpose of helping married couples with financial pwblems. During the four-year period noted above, respondent reported nearly all of the income he earned as a CPA for services he performed for accounting clients in the Foundation's tax returns. He falsely characterized almost all of his income during this period as money the Foundation received through lawful charitable activities, when in fact this was income earned for the accounting services he provided for private accounting clients.

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6. In 1998, respondent declared an individual gross income in the amount of $214,591. During the four subsequent years, which form bases of his four-count conviction, respondent ;reported business gross income from his CPA practice in the following amounts: $5,782 in 1999; zero in 2000; $4,956 in 2001; and $2,705 in 2002. Respondent reported low ·levels of income from 1999 thmugh 2002, despite the fact that his accounting practice was substantially the same as the 1998 tax-year when he reported a six-figure business income. Respondent filed individual tax retums for 1999-2002 on February 26, March 10, AprilS, and May 12, 2004 respectively. On each return, respondent declared under penalty of perjury that he "had examined the retum and accompanying schedules and statements, and to the best of [his] knowledge and belief, they are true, correct and complete.'' When respondent subscribed and filed the tax returns, he knew that they contained materially false information.

7. Most of the income that respondent earned during the above-referenced years, for performing work requiring a CPA certificate, was reported in the F om1dation' stax returns as charitable gifts, grants or contributions. In fact, this income was earned by respondent for preparing tax returns for clients (which amounted to 70 percent of the Foundation's stated income) and for counseling clients on financial and other issues (which amounted to 30 percent ofthe Foundation's stated income).

8. Respondent testified that the IRS was well aware that the Foundation would perform tax related services, including preparation of tax returns for individuals and corporations. Respondent's testimony is not credible. In respondent's application for exempt status under IRS Code section 501(c)(3) (application), he stated that the purpose of the Foundation was to "conduct basic social research in the emotional and psychological differences between men and women, to increase public awa1·eness about the importance of achieving and maintaining effective communication sldlls between married·couples and adults generally, and to instruct married couples about the multiple methods and techniques for wealth accumulation which may lead to a more stable and enduring marriage or relationship." There is nothing in the 19-page application, which states or indicates that the Foundation will perform tax return preparation services for individuals and corporations. Further, there is no indication in the application that the Foundation would generate income from the preparation of individual and corporate tax retums. The stated sources of income for the Foundation included "admission prices for seminars, ... grant funds received from other tax exempt foundations, gifts from the public, and contributions from respondent." (Exhibit 15.) Respondent's testimony that the application contained an attachment prepared by his attorney explaining that the Foundation would also prepare individual and corporate tax returns is not credible. This finding of lack of credibility is based on respondent's demeanor and the lack of or insufficiency of documentary evidence that might have suppmted his testimony.

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9. Respondent testified that he did not know that he was engaging in illegal or prohibited conduct. Respondent~s testimony is not pet·suasive. He had almost 20 yeat•s~ experience worldng as a CPA when he engaged in this fraudulent conduct. Under the facts ofthis case, an assertion of ignorance by a CPA with 20 yeru·s ~ experience is simply not credible. Once respondent became aware that he was being investigated and/or audited for the individual tax returns he filed in 2004 (fm tl1e 1999-2002 tax years), he stopped his four-'yeru· practice of intermingling and applying the income generated from his CPA practice to the Foundation.

10. Respondent submitted reference letters from Mends who know t·espondent well and attested to his honesty and integrity. Respondent has no other convictions.

11. Complainant requested reimbursement for costs of investigation and enforcement totaling $16,867.50 pursuant to Business and Professions Code sections 125.3 and5107 (Exhibit 4). The total costs requested include costs totaling $9,137.50 charged by the Department of Justice in 2012. However, Exhibit 4 does not contain a detailed summary of charges for the year 2012. Therefore, the total costs shall be reduced to $7,730.

LEGAL CONCLUSIONS

1. Cause exists to suspend or revoke the respondent's CPA certificate pursuant to Business and Professions Code sections 490 and 5100, subdivision (a), and 5106, based on respondent's four-count felony conviction set forth in Factual Finding 4.

2. Cause exists to suspend or revoke the respondent's CPA certificate pursuant to Business and Professions Code section 5100, subdivision (c), based on respondent's dishonest conduct underlying his conviction, as set forth in Factual Findings 5 and 6.

3. Cause exists to suspend or revoke the respondent's CPA certificate pursuant to Business and Professions Code section 5100, subdivision (i), based on respondent's conduct evidencing fiscal dishonesty by willfully preparing and subscribing four false federal individual income tax returns, as set forth in Factual Findings 4, 5 and 6.

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4. Cause exists to suspend or revoke the t·espondent's CPA certificate pursuant to Business and Professions Code section5100, subdivision G), based on respondent's conduct of knowingly preparing false, fraudulent and materially misleading financial statement, as set forth in Factual Findings 5 and 6.

5. Cause exists to suspend or revoke the respondent's CPA certificate pursuant to Business and Professions Code section 5100, subdivision (g), in that respondent willfully violated the Accountancy Act, and the rules and regulations promulgated by the Board pursuant to the Act.

6. Cause exists to suspend or revoke the CPA Partnership Certificate issued the Pybrum & Company, LLP under Business and Professions Code section 5101, subdivision . (a), based on Factual Findings 3 through 7.

7. Cause exists to order respondent to pay costs of enforcement in the amount of $7,730 based on Factual Finding 11.

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8, In its disciplinary guidelines, the Board has promulgated factors in aggravation and mitigation that the AU may consider in determining the level of discipline. Regarding aggravating factors, respondent knowingly committed serious misconduct over a four~year period. It was a premeditated and carefully thought~out plan. Further, respondent's testimony that he did not know that his conduct was illegal or prohibited is an indication that respondent does not recognize the seriousness of his wrongdoing. In applying the factors in mitigation, it is noted that is has been 12 years since respondent committed the offenses that resulted in his conviction and there is no evidence that respondent has engaged in misconduct since 2004. Further, respondent's conduct did not cause monetary loss to clients.

9. The Board has developed criteria for rehabilitation which are to be considered and applied when determining whether discipline should be imposed and/or the level. of appropriate discipline. These criteria, which are set forth in California Code of Regulations, title 16, section 99.1 include:

1. Nature and severity of the act(s) or offense(s).

2. Criminal record and evidence of any act(s) committed subsequent to the act(s) or offense(s) under consideration that . could also be considered as grounds for denial, suspension, or · revocation.

3. The time that has elapsed since commission of the act(s) or offense(s) referred to in subdivision (1) or (2).

4. The extent to which the applicant or respondent has complied with any terms of parole, probation, restitution, or any other sanctions lawfully imposed against the applicant o1· respondent.

5. If applicable, evidence of expungement proceedings pursuant to section 1203.4 of the Penal Code.

6. Evidence, if any, of rehabilitation submitted by the applicant or respondent.

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10. In this case, respondent committed felony offenses that are directly related to the duties, functions and qualifications of a CPA. Although l'espondent vyas ~onvicted of the offenses in 2012, respondent's n1.isconduct of filing false tax l'eturns occurred in 2004 (12 years ago). When respondent became aware that he was under investigation by the IRS and federal atlthorities, he stopped his four-year practice of intermingling and applying his . income from his CPA practice to the Foundation. Since his conviction, respondent has been in compliance with the terms of his probation and supervised release. However, respondent has not accepted responsibility for his criminal conduct. His testimony that he was not aware that his conduct was wrong is simply not credible, Further, respondent's assertion that, through his attorney, he informed the IRS that the Foundation would engage in tax preparation for individuals and corporations also lacked credibility. In consideration of all of the mitigating and aggravating factors and respondent's evidence of rehabilitation, the public . welfare dictates that revocation is the appropriate discipline in this case.

ORDER

1. Certified Public Accountant .No. 31088, previously issued to respondent Steven Mark Pybrum, is revoked.

2. Certified Public Accountant Partnership Certificate No. 7514, previously issued to Pybrum & Cmnpany, LLP, is revoked,

3. · Respondent Steven Mark Pybrum is hereby ordered to pay enforcement costs totaling $7,730 to the California Board of Accountancy.

DATED: October 7, 2016

f/~~HUMBERTO FLORES Administrative Law Judge Office of Administrative Hearings

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1 Accusation Against Steven MarkPybrum (Case No. AC-2013-36)

KAMALA D. HARRIS Attorney General of California ARMANDO ZAMBRANO Supervising Deputy Attorney General MATTI-ffiW A. KING Deptlty Attorney General State Bar No. 265691

300 So, Spring Street, Suite 1702 Los Angeles, CA 90013 matthew .king@doj .ca.gov (213) 897-7446 .

Attorneys for Complainant

BEFORE THE BOARD OF ACCOUNTANCY

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Against: Case No. AC-2013-36


Respondent.

Certified Public Accountant Partnership Certificate No. 7514,

Affiliated License.

STEVEN MARK PYBRUM P.O. Box 23209 Santa Barbara, CA 93121

PYBRUM & COMPANY, LLP Steven Pybrum, Jenna Salcedo, Partners P.O. Box 23209 Santa Barbara, CA 93121

ACCUSATION

(Gov. Code, § 11503.)

Complainant alleges:

PARTIES

1. Complainant Patti Bowers brings this Accusation solely in her official capacity as the

Executive Officer ofthe California Board of Accountancy (Board), Department of Consumer

Affairs,

mailto:[email protected]

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2 Accusation Against Steven Mark Pybrum (Case No. AC-2013-36)

2. On December 5, 1980, the Boat·d issued Cettified Public Accmmtant Certificate

Number 31088 to Respondent Steven Mark Pybrum. The Certified Public Accountant Cettificate

was in full force and effect at all times relevant to the charges brotlght in this Accusation, and will

expire on March 31, 2015 unless it is renewed.

3. · On October 23, 2012, the Boat·d issued Certified Public Account Partnership

Cel'tificate Ntmtber 7514 to Pybrum & Company, LLP, with Steven Pybn1m and Jenna Salcedo as

partners. The cettificate became effective two days before Respondent's conviction, and at least

eight yeru•s. aftet the conduct underlying it. Pybtum & Company, LLP's certificate was due ~o

exph·e on October 31, 2014. As of the filing of this Accusation, the certificate was pending

renewal.

JURISDICTION

4. This Accusation is brought before the Board under the authority of the following

laws. All section references are to the Btlsiness and Professions Code tm1ess otherwise indicated.

5. Section 5109 ofthe Code states:

The expiration, cancellation, forfeiture, or suspension of a license, practice privilege, or other authority to practice ptlblic accountru1cy by operation oflaw or by order or decision of the board ot a court of law, the p1aqement of a license on a retired status, or the voluntary surrender of a license by a licensee shall not deprive the board ofjurisdiction to commence or proceed with any investigation of or action or disciplinary proceeding against the licensee, or to render a decision suspending . or revoking the license.

STATUTORY PROVISIONS

6. Section 490 of the Code states in relevant part:

(a) In addition to any other action that a board is permitted to take against a licensee, a board may suspend or revoke a license on the gwund that the licensee has been convicted of a crime, if the crime is substantially related to the qualifications, fu11ctions, ot duties of the business or profession for which the license was issued.

(b) Notwithstanding any other provision of law, a board may exe1·cise ru1y authority to discipline a licensee for conviction of a crime that is independent of the authority granted under subdivision (a) only ifthe ci'iine is substantially related to the qualifications, functions, or duties of the business or profession for which the licensee's license was issued.

. (c) A conviction within the meaning of this section means a plea or verdict of guilty or a conviction following a plea of nolo contendere. An action that a board is permitted to take following the establishment of a conviction may be taken when

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the time for appeal has elapsed, or th<i judgment of conviction has been affirmed on appeal, or when an order granting pl'Obation is made suspending the imposition of sentence, irrespective of a subsequent Ol'der under Section1203.4 ofthe Penal Code,

7, Section 51 00 of the Cody states in relevant part:

After notice and hearing the board may revoke, suspend, m· t•efuse to renew any permit ot• cettificate granted under Atticle 4 (commencing with Section 5070) and Article 5 (cmmnencing with Section 5080), or may censtll'e the holder of that petmit ot certificate for unpt·ofessional conduct that includes, but is not limited to, one or any combination of the following causes:

(a) Conviction of any cl'ime substantially t·elated to the qualifications, functions and duties of a certified public accatmtant or a public accountant,

(c) Dishonesty, fratid, gl'Oss negligence, -or repeated negligent acts colll111,itted in the same or different engagements, for the same or different oliei1ts, or any combination of engagements or clients, each resulting i11 a 'violation of applicable professional standards that indicate a lack of competency in the practice of public accountancy ot in the performance of the booldceeping operations described in Section 5052.

· (g) Willful violation of this chapter or any rule or regulation promulgated by the boatd under the authority granted under this chapter.

(i) Fiscal dishonesty or breach offiduciary responsibility of any kind.

G) Knowing preparation, publication, or dissemination of false, fraudulent, or materially misleading financial statements, reports, or information.

8. Section 5101 of the Code states, in pertinent part:

After notice and hearing the board shall revoke the registration and permit to practice of a paltnership if at any thne it does not have all the qualifications prescribed by the section of this chapter undet which it qualified for registration. After notice and hearing the board may revoke, suspend or refuse to renew the permit to practice of a partnership o1· may censure the holder of such permit for any ofthe causes enumel'ated in Section5100 and for the following additional causes:

(a) The revocation or suspension of the certificate ot· tegistration ot the revocation o1· suspension of or refusal to renew the permit to practice of any partnet.

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4 Accusation Against Steven Mark J'ybrum (Case N9. AC-2013-36)

9. Section 5106 of the Code states:

A plea or verdict of guilty or a conviction following a plea of nolo contendere is deemed to be a conviction within the meaning of this article. The record of the conviction shall be conclusive evidence thereof. The board may order the certificate or permit suspended or revoked, or may decline to issue a certificate 01' permit, when the time for appeal has elapsed, ot· the judgment of conviction has been affirmed on appeal or when an order gl'anting probation is made, suspending the imposition of sentence, irrespective of a subsequent order under the provisions of Section 1203.4 of the Penal Code allowing such person to withdraw his plea of guilty and to entet· a plea of not guilty, or setting aside the verdict of guilty or dismissing the accusation, information or indictment.

10. Section 5116 ofthe Code states:

(a) The board, after appropriate notice and an opportunity for hearing, may order any licensee or applicant for licensure or examination to pay an administrative penalty as provided in this article as part of any disciplinary proceeding or other proceeding provided for in this chapter. ·

(b) The board may assess administrative penalties under one or more provisions of this article. However, the total administrative penalty to be paid by the licensee shall not exceed the amount of the highest administrative penalty authorized by this article~

(c) The board shall adopt regulations to establish criteria for assessing administrative penalties based upon factors, including, but not limited to, actual and potential consumer harm, nature and severity of the violation~ the role of the person in the violation, the person's ability to pay the administrative penalty, and the level of administrative penalty necessary to deter future violations of this chapter. '

(d) Administrative penalties assessed under this article shall be in addition to any other penalties or sanctions imposed on the licensee or other person, including, but not limited to, license revocation, license suspension, denial of the application for licensure, denial of the petition for reinstatement, or denial of admission to the licensing examination. Payment of these administrative penalties may be included as a condition ofprobation when probation is ordeted.

(e) All administrative penalties collected undet this atticle shall be deposited in the Accountancy Fund.

REGULATORY PROVISIONS

11. California Code of Regulations, title 16, section 99 states in relevant part:

For the purposes of denial, suspension, or i'evocation of a certificate or permit putsuant to Division 1.5 (commencing with Seotion475) ofthe Business an~ Professions Code, a crime or act shall be considered to be substantially telated to the qualifications, functions or duties of a certified public accountant or public accountant if to a substantial degree it evidences present or potential unfitness of a certified public accountant 01' public accountant to perform the functions authorized by his or her certificate or permit in a manner consistent with the public health, safety, or welfare. Such crimes or acts shall include but not be limited to those involving the following:

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5 Ac.cusation Against Steven Mark Pybrum (Case No. AC-2013-36)

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(a) Dishonesty, fraud, o1· breach of fiduciary responsibility of any kind;

(d) Violation of any ofthe provisions of Chapter 1, Division III ofthe Business and Professions Code o1· ~illful violation of any rule or regulation of the board. .

COST RECOVERY

12. Sections 125.3 and 51 07 of the Code provide, in pertinent part, that the Board may

l'eqtlest the administrative law judge to dh·ect a licentiate found to have committed a violation or

violations of the licensing act to pay a sum not to exceed the reasonable costs of the investigation

an,d enforcement of the case.

STATEMENT OF FACTS

13, On October 25,2012, a jury found Respondent guilty of four felony counts of

willfully making and subscribing to a false feder~l individual income tax return (26 u~s.c. §

7206, subd. (1)). On March 4, 2013, the United States District Court for the Cenu·al District of

California sentenced Respondent to 36 months in prison and ordered hhn to pay a special

assessment of $400. The court waived payment ofthe fine because Respondent could not pay it.

The court ordered that he be placed on one year of supervised probation following his release

from prison. (U.S.'v. StevenMarkPybrum (C~D.Cal., 2012, No. CR-V-00955).)

14. Respondent filed false individual income tax returns for calendar years 1999 to 2002.

He unde1·reportedindividual inc~me for four years as part of a sophisticated scheme to ayoid

paying taxes on money he earned from accounting services. In1998, he incorporated the

Foundation for Harmony aqd Happiness (Foundation) with the stated purpose of helping marded

~ouples with financial ptoblems. Respondent used the 50l(c)(3) charity to camouflage income

ftom accounting clients, many of whom were businesses. He falsely characterized substantially

all of his income as money the Foundation earned through lawful charitable activities when in

fact it was self-employment income.

15. Except for the operation of the fraud, Respondent's accounting p1·actice remained

essentially unchanged fl·om 1998 to 2002. Whereas in1998 Respondent declared individual g1·oss

income of $214,591, in 1999 he reported a loss of $33,916. The following year he declared a loss

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of$11,391. In 2001, he repOl'ted gross income of$17,868. In 2002, he declared gross income of

$27,393. Respondent's actual income fot• these years was substantially higher than what he

t•epotted,

16, Respondent filed the individual inconie tax returns for 1999-2002 on February 26,

March 10, AprilS, and May 12,2004, respectively. On each return, Respondent declared under

penalty ofperjury that he had "examined the retum and accompanying schedules and statements,

and to the best of [his] lmowl~dge and belief, they [we]re true, cOl'rect, and complete." When he

subscribed and filed the returns, he knew that they contained materially fals~ information, ·

FIRST CAUSE FOR DISCIPLINE

(Conviction of a Substantially Related Cri:me)

17. Respondent is subject to disciplinary action under Code sections 490, 5100,

subdivision (a), and 5106, in conjunction with California Code ofRegulations, title 16, section

99, in that Respondent committed a crime that is substantially related to the qualifications,

f1..mctions and duties of a certified public accountant. Complainant realleges paragraphs 13-16.

SECOND CAUSE FOR DISCIPLINE

(Dishonesty and Fraud)

18. · Respondent is subject to disciplinary action under Code section 5100, subdivision (c),

for dishonesty and fraud in that Respondent willfully made and subscribed to four false federal

individual income tax returns. Complainant realleges paragraphs 13-16.

THIRD CAUSE FOR DISCIPLINE

(Fiscal Dishonesty)

19. Respondent is subject to disciplinary action under Code section 5100, subdivision (i),

fot fiscal dishonesty in that Respondent willfully made and subscdbed to four false federal

individual income tax retums. Complainant realleges paragraphs 13-16.

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FOURTH CAUSE FOR DISCIPLINE

(Knowing Preparation of False Financial Information)

20. Respondent is subject to disciplina1•y aotiontmder Code section 5100, subdivisimi G),

for knowingly preparing false, ftaudtdent and materially misleading financial statements, reports

or information. Cmnpl8;inant realleges paragraphs 13-16.

FIFTH CAUSE FOR DISCIPLINE

(Willful Violation of Accountancy Act)

21. Respondent is subject to disciplinary action under Code section 5100, subdivision (g),

for willfnlly violating the Accountancy Act and rules and regulations promulgated by the Board

under the authotity ofthe Act. Complainant tealleges paragraphs 13-20.

OTHER MATTERS

22. Undet se~tion 5101, subdivision (a), ofthe Code, if Certified Public Account

Ce1'tificate Number 31088, issued to Respondent, is revoked ot suspended, then the Board shall

also revoke, suspend, o1· censure Certified Public Accountant Partnership Certificate Numbe1•

7514, issued to Pybrum & Company, LLP, with Steven Pybmm and Jenna Salcedo as partners.

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PRAYER

WHEREFORE, Complainant requests that a hearing be held on the mattet•s herein alleged,

and that following the hearing, the Board of Accountancy issue a decision:

1. Revoking or suspending or otherwise imposing discipline upon Certified PtJblic

Accotmtant Ce11:ificate Number 31088, isst~ed to Steven Mad( Py"j,rum;

2. Revoking or suspending or censuring Certified Public Accountant Partne1·ship

Cel'ti:ficate Number 7514, issued to Pybmm & Company, LLP, with Steven Mark Pybrum and

Jenna Salcedo as pa1iners, pm·suant to Business and Professions Code section 5100, subdivision

(a), in th~;: event that Certified Public Accountant Ce11:ificate Number 31088, issued to Steven

Mark Pybruin, is revoked or suspended;

3, Otdering Steven Mark Pybrllln to pay the Board the reasonable costs of the

investigation and enforcement ofthis case, pursuant to Business and Professions Code sections

125.3 and 5107;

4, Ordedng Steven Mark Pybrum to pay an administrative penalty pursuant to BtlSiness

and Professions Code .section 5116; and, .

5. Taking such other and fuliher action as deemed necessary and proper.

DATED: __ 2)~~·~____/'(?0~JS~--

LA2012508348/51287879

before the california board of accountancy … · steven made pybrum (1'espondent)...

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