Diesel Country Truck Stop, Inc. - Page 6




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          during Andy’s lawsuit, petitioner changed its methodology for               
          reporting sales and at that time Steve began giving the fuel pump           
          computer tapes to Roberts.  Before petitioner changed its method            
          for reporting sales, Roberts asked Steve for the fuel pump                  
          computer tapes and was told by Steve that these tapes had been              
          destroyed.                                                                  
               Roberts represented petitioner in the audit of petitioner’s            
          fiscal 1990 income tax, hereinafter sometimes referred to as the            
          income tax audit.  The income tax audit began around mid-1992.              
          During the income tax audit, Roberts gave petitioner’s                      
          bookkeeping records to respondent and met with a revenue agent              
          two or three times.  During the income tax audit, the revenue               
          agent gave to Roberts a form that asked, among other things, how            
          many gallons of diesel fuel petitioner sold each month.  Roberts            
          gave the form to Steve.  Steve responded that petitioner sold               
          200,000 gallons per month.                                                  
               B. Monthly Inventory Reconciliation Sheets                             
               Petitioner’s records include Monthly Inventory                         
          Reconciliation sheets, hereinafter sometimes referred to as                 
          MIR’s, which petitioner used to track diesel fuel inventory.                
          Petitioner’s records include a MIR for each month from July 1989            
          through June 1990, except for December 1989.  Each MIR includes             
          columns for opening inventory, deliveries, closing inventory by             
          dipstick reading, metered sales, and accumulated metered sales.             






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Last modified: May 25, 2011