Martin and Barbara Schachter - Page 4

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               Cal Ben's books and records were maintained and Cal Ben's              
          partnership tax returns were filed using a hybrid method of                 
          accounting under which the accrual method of accounting was used            
          to account for purchases and sales of Cal Ben's inventory of soap           
          products, and the cash method of accounting was used to account             
          for other miscellaneous items of income and for Cal Ben's general           
          business expenses.  Cal Ben's general business expenses were                
          recorded on a cash basis in a cash disbursements journal.                   
               From 1955 through 1987, petitioner Barbara Schachter and               
          Marcia Karp, David Karp’s wife, maintained on a part-time basis             
          the books and records of Cal Ben.  In January of 1987, a full-              
          time bookkeeper was hired and assumed bookkeeping                           
          responsibilities for Cal Ben.                                               
               Purchase orders from Cal Ben’s customers for soap products             
          generally were received in the offices of Cal Ben over the                  
          telephone.  Whoever received the telephone purchase orders                  
          prepared for each order a sales invoice.  A copy of each sales              
          invoice was sent to Cal Ben's warehouse to have the order filled.           
          A copy of each sales invoice was sent to the customers along with           
          the merchandise, and the original of each sales invoice was given           
          to petitioner.                                                              
               After reviewing sales invoices, petitioner generally would             
          forward the invoices to Cal Ben's bookkeepers.  Upon receipt of             
          sales invoices from petitioner, the bookkeepers recorded                    






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