Richard A. Cole, M.D. Inc. - Page 4

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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             
               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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