- 52 - In that reply, petitioner denied various affirmative allegations made by respondent in the amendment to answer but did not deny any of the affirmative allegations in that amendment to answer regarding the additional $42,913 of the cost of goods sold for 1993 that petitioner and Ms. Brodsky claimed in the 1993 Schedule C and that respondent alleged in respondent’s amendment to answer should be disallowed. OPINION Evidentiary Issues The first evidentiary issue involves certain entries listed in three separate workpapers prepared by certain of respondent’s employees (respondent’s workpapers), one for each of the years at issue. Each of those workpapers shows for each of those years certain information that is listed under various headings with respect to each of the deposits into petitioner’s accounts, including each of the payments against the balances due on petitioner’s credit accounts. One such heading is “Payor”. (We shall refer to the persons listed in respondent’s workpapers under the heading “Payor” as payors.) Ms. Martin prepared the respective workpapers for 1991 and 1992, and one or more of respondent’s other employees prepared the workpapers for 1993. Ms. Martin and one or more of respon- dent’s other employees prepared respondent’s workpapers by using information contained in certain documents that respondentPage: Previous 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 Next
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