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Roberts, Bedevian’s successor as petitioner’s accountant, did not
receive these tapes until Steve gave them to Roberts after Andy
sued Steve and petitioner. Before then, when Roberts asked for
these tapes, Steve responded that these tapes had been destroyed.
Thus, petitioner’s fuel pump computer tapes were not relied on in
the preparation of petitioner’s fiscal 1990 tax return, Steve
kept these tapes from petitioner’s accountants, and the one bit
of evidence we have as to these tapes’ accuracy is Hart’s mid-
1988 comparison of one tape with that day’s DSR which showed that
that tape’s total diesel sales amount was about $200 higher than
the DSR’s amount. We conclude that the evidence of record as to
petitioner’s fuel pump computer tapes supports respondent’s
determination to reconstruct petitioner’s diesel fuel sales
income.
Steve’s early 1998 letters to respondent repudiated the
MIR’s in total, and the second letter repudiated each month’s
MIR. See supra text at tables 1 and 2. We conclude that the
evidence of record as to petitioner’s MIR’s support respondent’s
determination to reconstruct petitioner’s diesel fuel sales
income.
Steve testified that petitioner’s employees copied the fuel
pump computer tapes information--gallons and dollars--onto the
DSR’s, and that the DSR’s and fuel pump computer tapes were then
sent on to Bedevian. Bedevian testified that he did not receive
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