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I. Oddo's Discovery That Bischoff Had Filed the Articles of
Incorporation
On October 11, 1990, Oddo called Mr. Moye and suggested that
it was time to incorporate the police dog training business
because it was the end of its first quarter of operations. Mr.
Moye told Oddo to call Bischoff. Oddo called Bischoff's office.
Bischoff's secretary told Oddo that Bischoff had already
incorporated petitioners' police dog training business. Oddo
decided to keep the books as if the police dog training business
were a sole proprietorship until the end of the year. The record
does not indicate whether Oddo discussed this with petitioners.
J. Bank Account, Business Records, and Tax Returns
1. Business Bank Account and Records
In 1990, petitioners conducted all of the banking for their
police dog training business through a bank account which was in
their individual names.
Oddo prepared a general ledger and general journal for
Southern Police Dog Academy for January 1 to December 31, 1990.
Under "Loans - officers & shareholders", the ledger and journal
lists several loans from petitioners.
On June 26, 1991, Oddo sent to petitioner at "Rosewood
Kennels d/b/a Southern Police Dog Academy" a balance sheet and
income statement for Southern Police Dog Academy as of December
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