- 15 - It is not enough for petitioners to claim that the entries recording loans to shareholder must have been made in error. The record makes it abundantly clear that petitioner was ignorant about financial and accounting concepts when he purchased Mid- Nebraska’s stock and continuing at least through the audit of petitioners’ 1993 return. It is also obvious that petitioner made no effort to acquaint himself with Mid-Nebraska’s financial records or the accounting entries made on those records or the data reported on the corporate tax returns. Petitioner testified that he did not know of what the loans to shareholder accounts consisted and that he was not even aware that Mid-Nebraska’s books reflected loans to shareholder until after York took over the corporation’s business. He testified further, however, that he did not understand the corporate books and relied totally on in-house bookkeepers to keep the corporate books and on outside accountants to prepare the corporate tax returns. He stated additionally that when he reviewed the corporate books, he checked only for the amount of premiums he had written each month. Petitioner failed to present any testimony from individuals involved in preparing Mid-Nebraska’s books and tax returns who could explain the nature of the loans to shareholder accounts included on Mid-Nebraska’s books or otherwise establish that the accounting entries were made in error. The failure of a party toPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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