Henry C. Boler and Sherry M. Boler - Page 6




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          C.   The Promissory Note                                                    
               On December 31, 1992, petitioner signed a promissory note on           
          behalf of AIM which stated that AIM would pay $121,596 to                   
          petitioner on demand, with interest to be paid annually at                  
          10 percent beginning on December 31, 1994, and ending December              
          31, 2000.                                                                   
               AIM reported on its 1992 income tax return that it had                 
          $121,596 in loans from stockholders.  AIM did not report any                
          loans from stockholders on its 1990 or 1991 return.                         
          D.   References to the Whittington Property and Related Debt in             
               AIM’s Financial Statements                                             
               1.   Application to the Mississippi Board of Contractors               
               On May 26, 1992, John C. Trussell III (Trussell), one of               
          petitioners’ certified public accountants, prepared a balance               
          sheet for AIM.  It stated that, on February 29, 1992, AIM owned             
          real estate worth $89,862 and owed $30,000 for “loans due to                
          stockholder.”  The balance sheet did not state that AIM owed                
          money to petitioner relating to the Whittington property.  On May           
          29, 1992, AIM applied to the Mississippi State Board of                     
          Contractors for a certificate of responsibility.  AIM included in           
          its application the balance sheet and a financial statement                 
          prepared by Trussell that contained the information shown on the            
          balance sheet.                                                              









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