- 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.                  
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