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None of the above personal expenses were ordinary and necessary
business expenses of JJH or petitioner. The checks to
petitioner, Charlene, Coastal, CCA, and Craig were for the
personal use of petitioner and his family. The checks to Tim and
the University of Central Florida were for Tim’s tuition, room
and board, and other college expenses. The automotive expenses
included petitioner’s monthly car payments, payments for gas, and
car maintenance expenses. The payments to the IRS were payments
for petitioner’s and Craig’s Federal income tax obligations.
2. CCA’s Account—CCA had a checking account over which
petitioner and Charlene had signatory authority. Charlene used
this account as her personal checking account. The deposits to
this account during 1994 included $16,100 in checks from JJH
written to Charlene and CCA and $9,000 in checks from Coastal.
Charlene also deposited receipts from her craft business into
this account, but she did not know what portion of the deposits
these receipts were. During 1994, Charlene wrote approximately
$30,569 in checks from this account, including $9,400 in checks
to JJH, $7,700 in checks to Charlene or Coastal, and other
miscellaneous checks to cover personal living expenses.
3. Coastal’s Account—Coastal had a checking account over
which Charlene and Craig had signatory authority, but petitioner
was in control of the account, and Charlene and Craig obtained
petitioner’s approval before using the funds. The Coastal
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