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Year Due Filed
1987 October 17, 1988 December 5, 1988
1988 October 15, 1989 November 13, 1989
1989 October 15, 1990 August 30, 1991
1990 August 15, 1991 August 15, 1991
Respondent determined in the notice of deficiency to the
individual petitioners additions to tax for delinquency computed
without regard to the extensions of time.
Petitioners relied almost entirely on their accountants for
purposes of taking care of the corporate petitioner's monthly and
yearly books and financial records, and corporate and personal
tax returns. For the corporate petitioner, Ms. Stroud relied
upon the green sheets prepared by Mr. Sutton and the corporate
bank statements. It is not clear what materials the individual
petitioners furnished to Ms. Stroud for the preparation of their
individual tax returns. However, Ms. Stroud did not have the
Suttons' personal bank statements when she prepared their
returns.
Respondent's Determinations
The Corporate Petitioner
Respondent reconstructed the corporate petitioner's income
for its taxable years ended September 30, 1987 through 1990,
based on the accounting and bank records that were available.
Revenue Agent Joseph Board (Mr. Board) compiled a list of
specific unexplained bank deposits for the corporate petitioner's
taxable years ended September 30, 1987 through 1989. Those
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