James J. Lencke and Janene B. Lencke - Page 8

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               Petitioners placed the receipts for Red Caboose's expenses,            
          along with some of the receipts for their personal expenses, in             
          manilla envelopes, but the receipts were not labeled personal or            
          business.  At the end of each year, working from memory, they               
          prepared a list of Red Caboose's expenses and attached the list             
          to the outside of the envelopes.  Petitioners could not have                
          presented a complete set of records for Red Caboose, separate               
          from their personal records, at any point during the years in               
          issue.                                                                      
               Mr Lencke deposited some of the proceeds from Red Caboose              
          into his Tippecanoe Agency account at Valley Federal Bank, which            
          was the account he had maintained as an insurance agent with                
          United Farm Bureau Insurance Companies.  The account no longer              
          contained funds from his former business as an insurance agent              
          when the Red Caboose proceeds were deposited.  Mr. Lencke's                 
          Social Security benefits were also deposited into the Tippecanoe            
          Agency account during the years in issue.  In fact, petitioners             
          used some of Mr. Lencke's Social Security benefits to fund Red              
          Caboose.  In addition, petitioners paid some of Red Caboose's               
          expenses with funds from their personal bank account.                       


          6(...continued)                                                             
          indicated that for 1990 and 1991 the sales were recorded in their           
          appointment book, and for 1992 the sales were recorded on a                 
          separate tally sheet for each show.  We have resolved this                  
          inconsistency by finding that for 1990 and 1991 the sales were              
          recorded in their personal appointment book, and for 1992 the               
          sales were recorded on a separate tally sheet for each show.                




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