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permission to sign her name to the West Pine checks. Mrs.
Gaskins believed that it was Mr. Quinn who was signing her name
to West Pine checks. Mrs. Gaskins permitted this practice,
accepting the explanation that he did not know anything about
the business, Mr. Quinn had the checkbook and was at the work
site, and this arrangement was more convenient. Mrs. Gaskins
knew Mr. Quinn was an officer of West Pine, the treasurer she
thought.
During the years 1979 through 1981, Mrs. Gaskins suspected
that West Pine had financial problems when Mr. Gaskins did not
give his paycheck to her at regular intervals. Mrs. Gaskins had
no knowledge of any unreported income which Mr. Gaskins received
from West Pine. See supra note 3.
Every 3 or 4 months, Mrs. Gaskins would make payments on
her 100-percent-penalty for the second roofing company in person
at the Pottsville IRS office. Occasionally, Mrs. Gaskins would
bring in information on Mr. Gaskins' 100-percent penalty for the
first roofing company. During Mrs. Gaskins' visits to the
Pottsville IRS office, she was distressed that she had been
assessed the 100-percent penalty, and Mr. Clark explained the
responsible person penalty to her. In her conversations with Mr.
Clark, Mrs. Gaskins denied she had any position or capacity with
West Pine.
In the latter half of 1981, Mr. Clark came into possession
of copies of some of West Pine's checks and bank signature
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