- 19 - 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 receivePage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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