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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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Last modified: May 25, 2011