- 57 - substantially understated the gross receipts of Design Consul- tants, including commissions received from Greyhound and/or Mayflower, for each of the years 1986, 1987, and 1988, (b) petitioners substantially understated the gross receipts of White Star for the year 1988, and (c) petitioners substantially understated their rental income for each of the years 1986, 1987, and 1988; (2)(a) Ms. Olbres recorded in the cash receipts jour- nals only those Design Consultants' and/or White Star's receipts that petitioners deposited into the Indian Head business checking account, and a person examining those journals and no other written records of Design Consultants and/or White Star would have no idea that Design Consultants and/or White Star received income in addition to their respective receipts that petitioners deposited into the Indian Head business checking account, and (b) a person examining both the cash receipts journals and the invoice logs that Ms. Olbres maintained would have no idea that Design Consultants and/or White Star received commissions in the amounts paid to them by Greyhound and/or Mayflower; (3) petition- ers failed to provide Mr. Dennett, their accountant, with com- plete information from which he could have accurately prepared their 1986, 1987, and 1988 returns; (4) the original invoice logs were not available at trial, and Ms. Olbres periodically de- stroyed the copies of portions of the invoice logs that she had brought to petitioners' house; (5) the testimony in this case ofPage: Previous 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 Next
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