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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 respondent
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