Anthony G. and Shirley A. Olbres - Page 57

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          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 of            






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