- 7 -7 When AJF suffered a shortage of drivers for its scheduled deliveries, it hired leased labor from Manpower Temporary Services. During 1988, 1989, and 1990, AJF claimed expenses for leased labor in the amounts of $5,074, $16,946, and $22,332, respectively. AJF also claimed deductions for "driver expenses" for 1988, 1989, and 1990 in the amounts of $37,172, $68,157, and $60,596, respectively. Respondent has allowed these deductions. Circumstances Surrounding Ferrentino's Cashing of AJF's Delivery Service and Fuel Reimbursements Checks During the years in issue, Ferrentino controlled all the checks issued from J.C. Penney to AJF. Ferrentino determined whether he would cash checks personally or have them deposited into AJF's corporate operating account. Ferrentino knew that AJF corporate income was determined by its accountants by examining deposits into AJF's bank account. AJF's gross income was determined from deposits to the bank account which were reflected in the cash receipts journal. He also knew that if the checks for fuel reimbursement and delivery services were not deposited into AJF's bank account, then corporate income tax returns would not reflect these amounts. J.C. Penney Custom Decorating Divisions (Custom Decorating) issued checks to "AJF and/or A.J. Ferrentino" for servicesPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011