William W. Halle IV, and Janice C. Halle - Page 29

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          the DAC system on December 31, 1990.  As a result of his                    
          forgetfulness, petitioner listed both the MYM expenses and the              
          DAC expenses on the scratch pads, added them together, and caused           
          the computer to copy the inflated figure onto his Schedule C.               
               There is no evidence that petitioner attempted to verify               
          whether the MYM expenses were already included in the DAC totals,           
          as in fact they were.  On the contrary, petitioner testified that           
          "I knew I had to get this return done.  It was April 15, and * *            
          * I had to get those figures in there.  And I just kind of --               
          just jumped into it and started keypunching".                               
               Petitioner personally created the DAC Ledger, DAC Accounting           
          Summary, DAC Accounts Payable Listing, and DAC Trial Balance on             
          his computer prior to April 15, 1991.  No one else made entries             
          for petitioner.  If copies of those records were unavailable on             
          April 15, 1991, petitioner had only to cause the computer to                
          generate another copy.  Petitioner should have reviewed his own             
          computer records, as both this Court and respondent have done, to           
          see that the MYM expenses should not have been listed on the                
          scratch pads in addition to the DAC expenses.  There is no                  
          explanation in the record as to why petitioner did not do so                
          other than his own testimony that his duplication errors were the           
          result of haste.                                                            
               Petitioner's contention that his records were complete and             
          carefully prepared is self-serving and not supported by the                 
          evidence.  The scratch pads were a key component of his tax                 




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