AJF Transportation Consultants, Inc., et al. - Page 11

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             under section 6501(a) expired before the issuance of the notices                                     
             of deficiency in these consolidated cases.                                                           
             Circumstances Surrounding the Late Filing of AJF's Tax Returns                                       
                    John Witkowski, C.P.A. (Witkowski), prepared AJF's tax                                        
             returns during the years in issue.  When preparing the returns,                                      
             Witkowski relied on AJF's books and records, which included                                          
             receipts journals, disbursement journals, payroll records, and                                       
             bank reconciliations.  Witkowski determined AJF's gross income                                       
             from AJF's cash receipts journal.  Expenses were determined using                                    
             check registers and cash-paid-out journals.  AJF's books and                                         
             records did not disclose amounts pertaining to the fuel                                              
             reimbursement checks from the J.C. Penney distribution centers,                                      
             nor did they disclose the Custom Decorating checks for delivery                                      
             services.                                                                                            
                   In general, after the returns were prepared for clients                                       
             including petitioners, Witkowski's office would contact the                                          
             client, who would normally pick them up.  If the client had not                                      
             picked them up after a reasonable length of time, Witkowski's                                        
             office would again contact the client.                                                               
                    Witkowski signed AJF's corporate returns for 1988, 1989, and                                  
             1990 on June 15, 1989, June 1, 1990, and July 8, 1991,                                               
             respectively.  For some unexplained reason, the 1988 and 1989                                        








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