- 6 - directed BNP to transfer $100,000 of the $840,000 to the Bank of America account. Sanrio mistakenly failed to issue a Form 1099 to petitioner for its payment of $840,000, because the payment was made via a wire transfer rather than through its accounts payable system. Petitioners and Sanrio never discussed the issuance of a Form 1099 upon the completion of the transaction. The BNP account was an interest-bearing account from which Susanna periodically transferred funds to the Bank of America account or to a checking account maintained at the Bank of the West. Except for the $840,000 from Sanrio, petitioners did not deposit any other business income directly into the BNP account in 1990; all other deposits in BNP were transfers from other accounts held by petitioners. C. Petitioners' Recordkeeping Methods Despite Susanna's accounting background, petitioner is Sand Hill's bookkeeper. He alone possessed signature authority over the Bank of America account. Petitioners used that account to deposit their commission checks, management fees, and reimbursed expenses. Whenever the Bank of America account held a particularly large balance, petitioner would transfer funds via check into other accounts, especially the BNP account, for the purpose of accruing greater interest. Petitioner claimed that when he wrote checks on the Bank of America account for deposit into another account, he did not verify that it containedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011