- 10 -
First, petitioners assert that Careswell's analysis
overstates the net difference by approximately $75,000. In part,
the difference between Careswell's analysis and petitioners' is
that Careswell analyzed the check exchanges on an annualized
basis, and petitioners' analysis is for a continuum beginning
January 2, 1989, through October 3, 1990. Petitioners then
further reduced the net excess from the check exchanges by
amounts of alleged jewelry sales to M&L in the approximate
amounts of $126,000 for 1989 and $176,000 for 1990. In addition,
petitioners deducted the $280,000 settlement paid by them to the
bankruptcy trustee in 1993 and 1994. By ignoring annual
accounting principles and by means of the other reductions from
Careswell's analysis, petitioners attempt to reduce the amount of
the net difference between M&L's and their check payments to
approximately $161,000, as opposed to the $691,995 developed in
Careswell's check exchange analysis.
Respondent contends that the reductions proposed by
petitioners are improper. For example, some of petitioners'
reductions are based on the presumption that Careswell included
in his check exchange analysis amounts that should have been
attributed to jewelry sales from petitioners to M&L. Respondent
contends that petitioners' financial records were inadequate to
permit accurate delineation between jewelry sales and M&L check
exchanges. In that regard it cannot be determined whether any of
those jewelry sales occurred and/or were included in part or
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011