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During the years in issue, Mrs. Beck occasionally worked in
Dr. Beck’s dental office and participated in recruiting employees
for his dental practice (the dental practice). A few times each
week, Mrs. Beck called the dental practice to ask the practice
administrator how much money the office received for the day.
Mrs. Beck was a signatory on the dental practice’s bank
account at Nation’s Bank (the dental practice account). From
December 1993 to January 1995, petitioners maintained a joint
personal account at Frost National Bank (the joint account). In
addition, from November 1994 through January 1996, Mrs. Beck was
the sole signatory to an account at Frost National Bank (the
separate account).
Dr. Beck employed a practice administrator who handled his
dental office affairs. The practice administrator would fill out
checks to pay substantially all of the dental practice expenses.
Either Dr. Beck or Mrs. Beck would sign the checks.
Dr. Beck accepted payment for his dental work in cash as
well as checks. The dental practice offered its services at a
discount if the patient paid cash. The dental practice employees
turned over to Dr. Beck all cash payments received.
During 1993 and 1994, the dental practice would receive
from its patients, on average, $3,000 a day in cash. From 1991
through 1994, only one cash deposit, in the amount of $2,000, was
made to the dental practice account.
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