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Mrs. Bacon also had a working knowledge of Radtam’s books
and records. Mrs. Bacon testified about the “settling” of daily
cash register receipts and the recording of Radtam’s income
during the years in issue. Mrs. Bacon prepared disbursement
summaries from Radtam’s account at Security Savings & Loan, which
were furnished to petitioners’ accountant. While Mr. Bacon
handled most of the deposits, Mrs. Bacon handled some deposits
and testified that she may have handled some large cash deposits.
5. Failure To Furnish Their Tax Return Preparer With
Accurate Information
The duty of filing accurate returns cannot be avoided by
placing responsibility upon an agent. See American Properties,
Inc. v. Commissioner, 28 T.C. 1100, 1116 (1957), affd. 262 F.2d
150 (9th Cir. 1958).
Beginning on or before July 1989, petitioners prepared a
monthly summary sheet on behalf of Radtam, which purportedly
listed total deposits into its bank accounts for that month.
These monthly summary sheets were furnished to petitioners’
accountant who prepared Radtam’s corporate tax returns24. In
addition to the monthly summary sheets, each month petitioners
provided their accountant with corporate bank statements and a
schedule of corporate disbursements.
24The same accountant prepared petitioners’ individual
Federal income tax returns and Bradam’s corporate Federal income
tax returns.
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