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and petitioner’s son’s lives, physical assaults, and manipulative
and controlling behavior.
During the years in issue, petitioner and intervenor
participated in Sign Sellers and Rocky Creations (the
businesses), which sold engraved stones and other items.
Petitioner designed the artwork that was etched onto the stones,
while intervenor maintained the business records and handled all
of the money. Occasionally, petitioner’s son worked for the
businesses and was paid on an hourly basis.
Petitioner and intervenor maintained at least five checking
accounts at various times during the years in issue, all of which
were used in the operation of the businesses. Intervenor had
signatory authority over four of the five checking accounts. The
fifth checking account (the Bank One account) was opened by
petitioner and petitioner’s son, and only they had signatory
authority. Intervenor instructed petitioner and petitioner’s son
to open the Bank One account. While intervenor did not have
signatory authority over the Bank One account, he exercised
complete control over the account. Intervenor instructed
petitioner what to deposit into the account and when. When
intervenor needed money, he instructed petitioner to sign a blank
check, and he filled in the rest.
With the aid of a tax return preparer, intervenor prepared
and filed joint Federal income tax returns for the years in
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Last modified: November 10, 2007