Dwight L. McKenna and Beverly S. McKenna - Page 11

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            1988 some of Mr. Gerdes' checks were returned to Circle Food                                
            Store for non-sufficient funds, or NSF.                                                     
                  Circle Food Store would assess Mr. Gerdes a $15 NSF charge.                           
            Ms. Hebert or another employee of Circle Food Store would usually                           
            go to Mr. Gerdes' office, and he would issue a replacement check                            
            to Circle Food Store, which included the amount of the check and                            
            the NSF fee.  At some point in 1988, Circle Food Store stopped                              
            cashing Mr. Gerdes' checks because he refused to pay the NSF                                
            charge, although he would issue another check for the amount of                             
            the overdraft check.  Circle Food Store never approached                                    
            petitioner and told him that he had to repay the amount he                                  
            received from one of Mr. Gerdes' checks.                                                    
            Petitioner's Cashing of Checks at Liberty Bank                                              
                  During 1987 petitioner cashed 60 income checks at Liberty                             
            Bank which were written by attorneys or other third parties.  The                           
            total amount of these checks was $37,540.  During 1988 petitioner                           
            cashed 40 third party checks at Liberty Bank.  The total amount                             
            of these check was $23,005.                                                                 
            Petitioner Beverly McKenna's Newspaper Business                                             
                  On their 1987 and 1988 joint Federal income tax returns,                              
            petitioners filed a second Schedule C for a newspaper business                              
            operated by Beverly McKenna.  For 1987 and 1988, the gross income                           
            and deductions were correctly reported.                                                     








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