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3. Petitioner's Business Receipts
Kathryn Hale (Ms. Hale) was petitioner's office manager for
the years at issue. Ms. Hale began working for Dr. Cole and
petitioner in 1980. At that time she was the only employee. She
answered phones, made appointments, took dictation, pulled
charts, and filed. Ms. Hale stopped working for Dr. Cole and
petitioner in May 1990. During those years, Dr. Cole hired
additional employees, such as Donna King-Deck (Ms. King-Deck) and
Trish Henderson (Ms. Henderson), and Ms. Hale became the office
manager.
Petitioner received cash and checks daily in fiscal years
1987 and 1988 from patients who received medical services from
Dr. Cole. Petitioner's business receipts were recorded each day
on "day sheets" for the years at issue and totaled for each day,
month, and year. Ms. Hale was responsible during the years at
issue for billing, handling patients' insurance, collecting
payments, and maintaining the day sheets. Ms. Hale usually made
the entries on the day sheets. Occasionally, Dr. Cole, Ms. King-
Deck, or Ms. Henderson made entries on the day sheets.
The day sheets included the patient's name, the service
provided, the fee for that service, and whether the patient paid
by cash or check. Receipts were totaled daily and carried
forward. The day sheet for the last day of the month showed the
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