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the fuel all cost petitioner less than what it charged the
drivers.
During the years at issue, petitioner did not have any
operating assets other than cash in a checking account. Mr.
Golden and his wife, Phyllis, were the only ones with signatory
authority on petitioner’s checking account. Checks that came in
from contracting companies such as IMC and Florida Favorite
Fertilizer were deposited in petitioner’s account, and the
Goldens wrote checks to pay the drivers and to pay expenses.
Deposits into petitioner’s checking account totaled $1,185,100.20
and $1,203,921 during 1994 and 1995, respectively. In 1993,
1994, and 1995, checks totaling $270,000, $186,000, and $202,100,
respectively, were drawn from petitioner’s account to Mr. Golden.
Amos Jackson, a tax consultant, prepared the 1993, 1994, and
1995 tax returns for petitioner. Mr. Golden provided Mr. Jackson
with the amounts of money petitioner had received from the
corporations for which petitioner performed transportation
services and also told Mr. Jackson that he had paid out equal
amounts to the drivers. Mr. Golden did not provide Mr. Jackson
with the ledgers or any other books or records regarding
petitioner.
Petitioner’s reported gross receipts for 1993, 1994, and
1995 were $1,336,876.73, $1,140,870, and $1,169,111,
respectively. Petitioner’s returns reflected deductions for
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