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Trisch doing business as DRD. Petitioner did not know about this
payment or the purchase of Thistlewood. Trisch and Lashley
operated the farm.
E. Income Tax Returns
1. DRD’s Returns
Petitioner sent DRD records that he had for 1989 to Dennis
Brady (Brady), DRD’s tax preparer at the time. Brady sent DRD’s
Form 1065, U.S. Partnership Return of Income, for 1989 to
petitioner. Petitioner sent it to Trisch. Trisch and Brady made
changes in the return. Petitioner did not see the 1989 return
after he sent it to Trisch. Trisch reported engineering income
on DRD’s 1989 return. The record does not show whether the
engineering income was reported on the DRD return petitioner saw,
and DRD’s 1989 return does not specify that the amount reported
is engineering income. John L. Givens III (Givens), C.P.A., who
was Trisch and Lashley’s accountant, replaced Brady as DRD’s
accountant on a date not stated in the record.
Trisch gave the accountants who prepared DRD’s tax returns
for 1990 through 1993 summaries of DRD’s income and expenses for
those years. The engineering income reported on DRD’s tax
returns was largely offset by the deduction of payments made for
personal expenses of Trisch, Lashley, and their family members.
Trisch signed DRD’s tax returns for the years in issue.
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