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In further support of their contention that Mr. Dennett made
errors in preparing petitioners' returns for the years at issue,
petitioners offered the testimony of Ms. LaPlante. Throughout
the period 1981 through around 1991, Ms. LaPlante, as head
bookkeeper for the town of Hampton, worked with Mr. Dennett in
his capacity as town treasurer. Ms. LaPlante testified that,
during the late 1980's, she noticed that Mr. Dennett made a
number of mistakes in the treasurer's reports that he was re-
quired to prepare and provide to her and that he was three months
delinquent in providing her with one of those reports. From 1981
through around 1993, the period during which Ms. LaPlante, who
had graduated from high school and attended two years of college,
was head bookkeeper for the town of Hampton, she was not an
accountant. Moreover, in a "letter of comments and recommenda-
tions" dated January 31, 1990, and prepared by Plodzik & Sander-
son, an accounting firm retained by the town of Hampton to
conduct audits of the town, that firm made the following comments
about Ms. LaPlante: "While * * * [she] does attempt to maintain
some of the required records, we do not feel that she possesses
the necessary skills to assume responsibility over all bookkeep-
ing and record-keeping functions". On the record before us, we
are unwilling to find from Ms. LaPlante's testimony that Mr.
Dennett made mistakes in his treasurer's reports during the
1980's, nor are we willing to infer from her testimony that Mr.
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