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Accu-Data
On December 16, 1980, Mr. Morris incorporated Accu-Data for
the purpose of operating an accounting and tax return preparation
business. He was the sole stockholder of Accu-Data until its
involuntary dissolution on May 1, 1992. During the years at
issue, (1) Mr. Morris maintained a checking account on behalf of
Accu-Data at the Champaign National Bank (Accu-Data account) on
which he was the sole signatory and into which he deposited
certain of the embezzled funds; and (2) petitioner had no in-
volvement with Accu-Data or that account.
As president of Accu-Data, Mr. Morris signed the Form 1120-A
that it filed for its taxable year ended June 30, 1988, and the
Forms 1120S that it filed for its taxable years 1988 and 1989.6
Trust 768
Trust 768 was created on November 23, 1987. At that time,
the beneficial interests in Trust 768 were held equally by
(1) John Kenny Company and (2) petitioner and Mr. Morris. On
February 9, 1988, John Kenny Company assigned its beneficial
6 Prior to July 1, 1988, Accu-Data was not an S corporation, and
it had a taxable year that ended on June 30. It appears that
Accu-Data became an S corporation on July 1, 1988, and thereafter
adopted the calendar year as its taxable year. The Form 1120S
that Accu-Data filed for its taxable year 1988 covered the last
six months of that year.
Mr. Morris prepared the Form 1120-A that Accu-Data filed for
its taxable year ended June 30, 1988. It is unclear from the
record who prepared the Forms 1120S that Accu-Data filed for 1988
and 1989.
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