William O. Harrison - Page 6

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             Petitioner's Books and Records                                           
                  Ms. Lynn Cates was petitioner's bookkeeper from 1983                
             through the years in issue.  She worked in an office that                
             petitioner maintained during the years in issue in Corpus                
             Christi.  Ms. Cates used a journal bookkeeping system                    
             referred to as the "One Write System" to record                          
             petitioner's cash disbursements and deposits.  All of                    
             the checks in petitioner's checkbook were made with a                    
             carbon backing so that anything written on a check was                   
             automatically copied into a journal.  Ms. Cates reconciled               
             the entries in the journal with petitioner's bank account                
             each month.  In 1989, she established a general ledger                   
             system which she used in addition to the "One Write                      
             System".                                                                 
                  Ms. Cates had no bookkeeping experience when she                    
             started working for petitioner in 1983.  She received                    
             some initial training from petitioner's previous bookkeeper              
             and some additional training from Ms. Elizabeth Ruble, a                 
             certified public accountant, who was involved in the                     
             preparation of petitioners' 1988, 1989, and 1990 returns,                
             as further described below.  Ms. Cates took a basic                      
             accounting class and a computer accounting class in 1985.                
                                                                                     






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