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were printed numerically by geographical region in Mexico.
Generally, client statements were hand delivered by
promoters to clients. The client statements either were picked
up in San Antonio by a promoter from Mexico and taken to Mexico
or were taken by someone from San Antonio to Mexico. After mid-
1988, INC transferred the information in the client statements
onto a computer tape and transported the tape to Mexico City
where the statements were printed and sent to the promoters for
distribution to LTD’s clients.
I. IRS Audit During Spring 1987
During the spring of 1987, the IRS notified INC that it
would be the subject of an audit. After INC became aware of the
upcoming audit, Mr. Dooley took LTD's general ledger to the
Cayman Islands. Additionally, LTD's journal vouchers were sent
to the Cayman Islands. The lower-level documents, however,
remained in San Antonio. Mr. Dooley took the general ledger to
the firm that LTD used to maintain its registration in the Cayman
Islands and discussed the logistics of having the firm maintain
the general ledger.
Mr. Zollino decided, however, to begin maintaining LTD's
general ledger in Mexico. Journal vouchers, which were used to
make entries into LTD's general ledger, were still being produced
in San Antonio. Accordingly, David Rodriguez, an INC employee,
was sent to Mexico with the journal vouchers, which were entered
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