Cordes Finance Corporation - Page 9

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                information directly from Citizens Bank.  Pursuant to the                                
                summons, the bank produced petitioner's deposit records for                              
                the months of January, November, and December 1990.  After                               
                comparing petitioner's deposits during these 3 months with                               
                the cash amounts recorded in petitioner's cash receipts                                  
                journal, the agent found that petitioner had omitted                                     
                $127,889 of income from its 1990 return.  Respondent's                                   
                agent found the following omitted amounts:                                               

                      Month                   Omitted Amount                                             
                            January           $56,893                                                    
                            November          38,246                                                     
                            December               32,750                                                
                            Total             127,889                                                    

                      Respondent's agent also found that the above-omitted                               
                income had been posted to a liability account, account                                   
                312, characterized as a shareholder loan account, as if                                  
                petitioner's stockholders, members of the Cordes family,                                 
                had advanced funds to petitioner.  Mr. Cordes had                                        
                instructed petitioner's bookkeeper to post certain receipts                              
                as credits to account 312 and not as income.  This was true                              
                for bankruptcy collections with respect to debts that had                                
                been written off, late charge fees related to outstanding                                
                loans, and sundry other receipts.  Mr. Cordes and his                                    
                family were able to draw upon account 312 to pay personal                                
                expenses.  Petitioner concedes that it omitted the above                                 
                amounts from its 1990 return.                                                            



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