- 4 - tax returns. During those years, Lesile Delmarter (Mr. Delmarter), a certified public accountant employed by that firm, was responsible for the supervision and performance of those services. In providing those services to petitioner, employees of PKF, including Mr. Delmarter, relied on the records, such as check registers, check stubs, bank statements, and canceled checks, that petitioner forwarded to PKF relating to her finan- cial transactions. Mr. Delmarter and other employees of PKF followed whatever characterization petitioner had reflected in those records as to the nature of her transactions and did not independently determine whether those characterizations accurate- ly reflected the nature of those transactions. For example, if petitioner had noted on a check stub that a check she wrote was a loan, Mr. Delmarter and other employees of PKF accepted that notation as accurately indicating the purpose for which that check was written. Petitioner's Transfer to Stephen Petitioner transferred $100,000 to her son Stephen by giving him two $50,000 checks on June 18, 1982, and on September 9, 1982, respectively. Petitioner wrote the word "loan" on the check register and the check stub, respectively, for those checks, and she sent those check records to PKF. Because peti- tioner had written the word "loan" on those records, on December 31, 1982, PKF recorded each of the $50,000 checks petitionerPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011