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the sole proprietor of a computer consulting business that
included the delivery of computer equipment and the setting up of
computerized bookkeeping and payroll systems.4 Petitioner
installed computer equipment for PAHHS and BHHS and set up their
computerized bookkeeping and payroll systems. He also taught the
employees of PAHHS and BHHS how to use the systems. Such
computerized bookkeeping and payroll systems that were set up by
petitioner included the four payroll checking accounts and the
four general checking accounts maintained by PAHHS and BHHS that
are referred to above. Petitioner also installed computers in
the offices of other corporations operated by Dr. Constant.
During 1988, petitioner also worked as a “handyman” for BHHS,
setting up offices and moving boxes and furniture.
During 1988, Ms. Dawson caused checks to be issued to
herself from the payroll checking accounts maintained by PAHHS
and BHHS for her wages from the corporations in the amounts of
$35,903.12 and $33,854.68, respectively. Also during that year,
in addition to the checks for her wages, she used the
computerized payroll system installed by petitioner to cause
checks to be issued to herself from the payroll checking accounts
in the amount of $153,726. Ms. Dawson signed each of the checks
4
Petitioner operated such business from the middle of 1987
through the end of 1989.
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