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In 1984 or 1985, petitioner became a client of Sahag
Bedevian (hereinafter sometimes referred to as Bedevian), who
provided income tax and bookkeeping services to petitioner.
Steve was petitioner’s primary contact with Bedevian. Bedevian
developed the DSR form for Steve to track petitioner’s income and
bank deposits. Bedevian advised Steve to keep all fuel pump
computer tapes and records relating to diesel fuel sales in a
safe place. Bedevian told Steve that if petitioner were audited
then the auditor would need fuel pump computer tapes and records.
Steve did not provide the fuel pump computer tapes to Bedevian.
Bedevian prepared the tax return for petitioner’s fiscal 1990,
which Bedevian signed as tax return preparer on September 10,
1990. This tax return was filed on September 20, 1990.
In January or February of 1991, Grey Roberts (hereinafter
sometimes referred to as Roberts), a C.P.A., replaced Bedevian as
petitioner’s accountant. Roberts was petitioner’s accountant for
about 3� years. During his work with petitioner, Roberts dealt
primarily with Steve. When Roberts became petitioner’s
accountant, he received petitioner’s records from Bedevian. The
records Roberts received did not include any fuel pump computer
tapes. Steve did not provide fuel pump computer tapes to Roberts
until after Andy filed a lawsuit against Steve and petitioner;
that lawsuit was filed at some point after the beginning of the
income tax audit that led to the instant case. At some point
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