Nick Kikalos and Helen Kikalos - Page 10

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               As a first step, respondent reviewed copies of third party             
          checks that petitioner used to purchase cashier’s checks.  During           
          1997 petitioner purchased in excess of $800,000 in cashier’s                
          checks with cash, and negotiated third party business and                   
          personal checks.  Petitioner testified that he purchased the                
          cashier’s checks to protect his money in case of a bank failure.            
          He also testified that one of his objectives in using third party           
          checks to purchase cashier’s checks was to prevent the bank from            
          reporting cash transactions exceeding $10,000 to the Internal               
          Revenue Service.  Significantly, petitioner failed to provide any           
          documentation to show that the third party checks used to                   
          purchase cashier’s checks were included in business gross                   
          receipts.  Finally, petitioner’s accountant testified that she              
          had no knowledge of the existence of the cashier’s checks.                  
               Because petitioner presented no evidence to account for the            
          third party checks, respondent designated checks from cigarette             
          manufacturers, and not related to other types of income, as                 
          coupon and buy-down receipt checks.  Checks totaling $531,605 fit           
          into that category.                                                         
               In addition, petitioner’s accountant made a $400,746                   
          accounting entry in petitioner’s October 1997 records with                  
          respect to checks received from cigarette manufacturers.                    
          Respondent accepted that entry as reflecting payments received              
          from cigarette manufacturers.  Because no activity was recorded             






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