G.B. Data Systems, Inc. - Page 17




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          that during 1994, approximately eight months after the close of               
          petitioner’s fiscal and taxable years ended January 31, 1994, Ms.             
          Wu, petitioner’s controller, sent Mr. Miller the purported                    
          product usage document.11  She provided that document to Mr.                  
          Miller in order to have him (1) prepare and book on petitioner’s              
          behalf certain accounting entries and (2) reflect such accounting             
          entries in the Form 1120 that he was preparing on petitioner’s                
          behalf for the year at issue.  Based on the purported product                 
          usage document, Mr. Miller prepared adjusting journal entries in              
          September 1994 that debited royalty expense and credited royal-               
          ties payable in the amount of $1,158,084.  The amount of those                
          entries was the same as the amount shown on the purported product             
          usage document as the last entry under the column headed “NET                 
          TOTAL (IN BOTTLES)”.  After having prepared the royalty adjusting             
          journal entries, Mr. Miller completed preparation of petitioner’s             
          Form 1120 for the year at issue based upon those entries and                  
          petitioner’s financial statements for the fiscal year ended                   
          January 31, 1994.  Thereafter, but prior to booking the royalty               
          adjusting journal entries in petitioner’s books and prior to                  
          filing petitioner’s return for the year at issue, Mr. Miller                  
          confirmed with Mr. Braswell the correctness of booking those                  





               11See supra note 9.                                                      





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