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administrative files and creating backup for bank statements,
accounts receivable, and notes payable. She worked on
petitioner's personal accounts and business accounts, including
M&S and Interservice. G. Rodriguez gathered information for use
by Boldt, who prepared petitioner's 1990 Federal income tax
return.
As part of G. Rodriguez's duties, she prepared various
ledger sheets reflecting transfers of funds into and out of
petitioner's business and personal accounts. On numerous
occasions, G. Rodriguez inquired as to the source of the funds in
an attempt to perform her duties and to reconcile the accounts.
She was instructed by petitioner to label many of the transfers
as payments from or amounts payable to either "Mexican Company"
or petitioner's wife. She was never told the name of the Mexican
company or the reason that a Mexican company would be
transferring funds to petitioner. She was not aware of any loans
from petitioner's wife. Other financial reports that were
prepared by G. Rodriguez for petitioner listed the source of the
funds as "??" because petitioner would not provide her with the
source of the deposits.
Petitioner left for Mexico in the beginning of July 1991
because his mother was terminally ill. During that same time,
G. Rodriguez was contacted by U.S. Government authorities,
specifically U.S. Customs and the Internal Revenue Service (IRS),
regarding the activities of petitioner. The Government was
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