Anthony G. and Shirley A. Olbres - Page 54

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          Dennett made errors in his preparation of petitioners' returns              
          for the years at issue.                                                     
               In order to provide additional support for their contention            
          that Mr. Dennett made errors in his preparation of their returns            
          for the years at issue, petitioners assert that Mr. Dennett                 
          should have known that their income in each such return was                 
          understated because he prepared (1) the unaudited projected                 
          financial statements for Design Consultants for 1986, which                 
          reflected projected gross receipts in an amount that is almost              
          twice as large as the gross receipts reported by petitioners in             
          their 1986 Schedule C, and (2) the unaudited projected financial            
          statements for White Star for 1988, which reflected projected               
          gross receipts in an amount that is almost four times as large as           
          those reported by White Star in its 1988 Form 1120S.17  Peti-               
          tioners further contend that the August 31, 1988 unaudited                  
          personal financial statements reflected their assets on a "com-             
          plete and accurate basis" and that those assets could not have              
          been accumulated with the income that they reported in their                
          returns for the years at issue.                                             

          17  Although Mr. Olbres asked Mr. Dennett to prepare both per-              
          sonal and business unaudited financial statements throughout the            
          approximate 14-year period during which petitioners retained Mr.            
          Dennett, Mr. Olbres testified at trial that he did not know the             
          meaning of the term "unaudited".  We are incredulous that Mr.               
          Olbres, who was in control of a multimillion dollar business and            
          who had many unaudited financial statements prepared for peti-              
          tioners and their business, did not know the meaning of that                
          term.                                                                       





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