Martin and Barbara Schachter - Page 5

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          information relating to the sales reflected by the invoices in              
          Cal Ben’s sales journal (reported sales).                                   
               During at least 1985, 1986, 1987, and 1988, however,                   
          petitioner did not forward to Cal Ben's bookkeepers all of Cal              
          Ben's sales invoices.  As a result, sales associated with                   
          invoices not forwarded to Cal Ben's bookkeepers were not                    
          reflected as sales in Cal Ben’s sales journal (unreported sales).           
               Cal Ben's sales invoices were not identified by number, and            
          therefore unreported sales could not be easily detected and                 
          identified.                                                                 
               Petitioner generally opened mail containing payments                   
          received from Cal Ben's customers.  Payments received relating to           
          reported sales were deposited into Cal Ben’s bank accounts at Bay           
          Bank of Commerce.  With regard, however, to payments received               
          relating to unreported sales, petitioner or David Karp would                
          prepare bank deposit slips and would deposit the payments into              
          the Lloyds/Sanwa account.                                                   
               Petitioners were aware of the existence of the Lloyds/Sanwa            
          account, and they were aware that unreported sales were not                 
          recorded in Cal Ben’s sales journal.                                        
               During 1985 through 1988, payments received on sales of Cal            
          Ben's soap products were deposited into the above three bank                
          accounts in the following amounts:                                          








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