AJF Transportation Consultants, Inc., et al. - Page 7

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               When AJF suffered a shortage of drivers for its scheduled              
          deliveries, it hired leased labor from Manpower Temporary                   
          Services.  During 1988, 1989, and 1990, AJF claimed expenses for            
          leased labor in the amounts of $5,074, $16,946, and $22,332,                
          respectively.  AJF also claimed deductions for "driver expenses"            
          for 1988, 1989, and 1990 in the amounts of $37,172, $68,157, and            
          $60,596, respectively.  Respondent has allowed these deductions.            
          Circumstances Surrounding Ferrentino's Cashing of AJF's Delivery            
          Service and Fuel Reimbursements Checks                                      
               During the years in issue, Ferrentino controlled all the               
          checks issued from J.C. Penney to AJF.  Ferrentino determined               
          whether he would cash checks personally or have them deposited              
          into AJF's corporate operating account.  Ferrentino knew that AJF           
          corporate income was determined by its accountants by examining             
          deposits into AJF's bank account.  AJF's gross income was                   
          determined from deposits to the bank account which were reflected           
          in the cash receipts journal.  He also knew that if the checks              
          for fuel reimbursement and delivery services were not deposited             
          into AJF's bank account, then corporate income tax returns would            
          not reflect these amounts.                                                  
               J.C. Penney Custom Decorating Divisions (Custom Decorating)            
          issued checks to "AJF and/or A.J. Ferrentino" for services                  









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