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With respect to the unaudited projected financial statements
for Design Consultants for 1986, those statements were merely
projections made by petitioners that included caveats indicating
that the figures in those statements were based on representa-
tions of petitioners, Mr. Dennett took no responsibility for
their accuracy, and he did not take responsibility to update
those figures. Mr. Dennett would have had no way of knowing
whether or not the projections in those financial statements
proved true at the end of that year, other than based on informa-
tion that petitioners provided to him. In this connection, it is
noteworthy that Mr. Dennett prepared a draft, unaudited statement
of income and expenditures for 1986 for Design Consultants based
on information provided to him by petitioners and that, unlike
the unaudited projected financial statements for Design Consul-
tants for 1986, that statement reflected gross receipts and net
income in amounts identical to the gross receipts and net income
reported in petitioners' 1986 Schedule C.
With respect to the unaudited projected financial statements
for White Star for 1988, as with the unaudited projected finan-
cial statements for Design Consultants for 1986, those statements
were merely projections made by petitioners that included caveats
that were virtually identical (except for one paragraph not
pertinent here) to those in the unaudited projected financial
statements for Design Consultants for 1986. Mr. Dennett would
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