Dennis W. Stark - Page 6



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          believed had previously been unreported by Lakeview.  It was                
          petitioner's belief that Lakeview had failed to report income               
          from cash sales in those years, due to William's practice of                
          removing all or most cash from the register and splitting it with           
          petitioner.  The accountant computed a ratio of cash to other               
          sales for the then-most recent 18-month period, and on the basis            
          of that ratio computed an estimate of the cash sales that may               
          have occurred, but were not reported, for the years 1984 through            
          1990.  On the basis of these estimates, the accountant prepared             
          amended returns for Lakeview that reported additional income in             
          each of the foregoing years.  There are no work papers, corporate           
          records, or other documentation in the record that support the              
          accountant's estimates.                                                     
               In December 1992, Amended U.S. Corporation Income Tax                  
          Returns (Forms 1120X) for Lakeview's 1984, 1985, 1986, 1987, and            
          1988 taxable years, and amended U.S. Income Tax Returns for an S            
          Corporation (Forms 1120S) for Lakeview's 1989 and 1990 taxable              
          years, were prepared and signed by the accountant as return                 
          preparer.  The returns were subsequently filed on an unknown                
          date.  The returns reported previously unreported income of                 
          Lakeview totaling $189,098.  Petitioner filed Amended U.S.                  
          Individual Income Tax Returns (Forms 1040X) for his 1989 and 1990           
          taxable years reporting his allocable share of the previously               
          unreported income reported on Lakeview's amended returns for                
          those years.                                                                
               Sometime in December 1992, petitioner caused to be prepared            



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