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Background4
Petitioner’s principal place of business at the time of the
filing of the petition in this case was Mableton, Georgia.
Petitioner, a subchapter C corporation, is a general contractor
engaged in the business of pumping concrete. During the 1992,
1993, and 1994 tax years, Alan Bone (Bone) and Jeffrey Guerrero
(Guerrero) owned 51 percent and 49 percent, respectively, of its
common stock.
Understatement of Gross Receipts
Findings of Fact
Respondent conducted an examination of petitioner’s 1992
through 1994 tax years. In connection with an analysis of
petitioner’s reported receipts for the 1992 through 1994 tax
years, respondent’s agent, Ronald Harkins (Agent Harkins),
performed bank deposits analyses of petitioner. For 1992, Agent
Harkins received the analysis that petitioner prepared for the
purpose of assisting him during the examination. Petitioner’s
analysis reflected the items that petitioner had included in
gross receipts. On the basis of that analysis of petitioner’s
bank deposits for the 1992 tax year, Agent Harkins concluded that
4 The parties’ stipulated facts and exhibits are
incorporated herein by this reference. Because this case
involves numerous adjustments and/or issues for our
consideration, we have found general facts under the title
“Background”, and facts specific to each issue are found
separately within the separately captioned sections of the
opinion considering each specific adjustment or issue.
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