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and hauling services. The dispatch services portion of the
payments was $18,063, which was deposited into petitioners'
personal bank account. Petitioners conceded that neither
Ruckman, Inc., nor petitioners reported the $18,063 in payments
for dispatch services from Happy Trucking on their Federal income
tax returns for 1991.
Mrs. Ruckman maintained both Ruckman, Inc.'s and
petitioners' financial records during the years at issue. She
kept spreadsheets listing income and expenses on handwritten
columnar pads. For each of the years in issue, Mrs. Ruckman
delivered the spreadsheets, bank account information, and Forms
1099 to Stanley Adkins, a certified public accountant, in order
for Mr. Adkins to prepare Federal income tax returns for
petitioners and for Ruckman, Inc. Mr. Ruckman relied on Mrs.
Ruckman to manage petitioners' and Ruckman, Inc.'s financial
records and did not participate in these matters to any
significant degree.
In June 1991, Mrs. Ruckman was diagnosed with cancer and
underwent surgery in that month and again in July 1991. Mrs.
Ruckman then commenced radiation and chemotherapy treatments in
August 1991. The radiation treatments lasted through September
1991 and the chemotherapy through March 1992. These treatments
required almost daily trips to Roanoke, Virginia, and prevented
Mrs. Ruckman from performing her regular work. Mr. Ruckman and
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