- 11 -11 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 1989Page: 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