- 34 - John Kenny Company, but also for Accu-Data on accounting and tax preparation matters. Although Mr. Morris discussed his employ- ment with petitioner in terms of the people with whom he worked, he generally did not inform her about what he actually did in his employment. Mr. Morris was not open with petitioner about his financial affairs, and, when she questioned him about those matters, he reacted negatively, causing her to discontinue that line of inquiry. Under the circumstances presented here, we find that it was not unreasonable for petitioner, who had no involvement with Accu-Data, to have believed that during the years at issue Accu- Data generated significant funds from an accounting and tax preparation business.25 We further find that, under those circumstances, it was not unreasonable for petitioner to have believed that during those years Meadows was capable of generat- ing significant amounts of gross receipts from the sale of sand and gravel.26 We have found that Mr. Morris controlled the affairs of Meadows during the years at issue, that petitioner was not involved in its day-to-day operations during those years, and that she was not in a position to know how much income Meadows 25 In fact, Accu-Data reported gross receipts of (1) $35,210 and $31,687 in its Forms 1120-A for its taxable years ended June 30, 1987, and June 30, 1988, (2) $20,647 in its Form 1120S for its short taxable year July 1 through Dec. 31, 1988, and (3) $6,000 in its Form 1120S for its taxable year 1989. 26 In fact, Meadows reported $22,482 and $86,355 of gross re- ceipts in the Forms 1120S that it filed for 1988 and 1989.Page: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 Next
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