- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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