Joseph A. and Carol DelVecchio - Page 6




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               Joseph was familiar with the peg board and other aspects of            
          Monterey’s bookkeeping system.                                              
          Sales and Bank Deposits                                                     
               Generally, Monterey received payments for glass by check.              
          Information as to all receipts was entered on the peg board, and            
          the receipts were deposited into Monterey’s account at First                
          National Bank and Trust Company (the Monterey account).  Monterey           
          deposited $994,058.25 and $926,963.35 into the Monterey account             
          during 1987 and 1988, respectively.                                         
          Withdrawals                                                                 
               Monthly, during 1987 and 1988, Joseph examined statements              
          showing the balance of the Monterey bank account and withdrew               
          funds in excess of the amount needed to operate the business.  He           
          deposited such excess funds, in the amounts of $111,200 and                 
          $74,880, during 1987 and 1988, respectively, into interest                  
          bearing accounts in his own name.                                           
          Original Tax Returns                                                        
               Petitioners timely filed Forms 1040, U.S. Individual Income            
          Tax Return, for 1987 and 1988 (the Forms 1040).  Attached to the            
          Forms 1040 were Schedules C, Profit or (Loss) From Business or              
          Profession, which relate to Monterey (the Schedules C).  Joseph             
          prepared the Forms 1040 (including the Schedules C).  In                    
          preparing the Schedules C, as source documents, Joseph had                  
          available the peg board, vendor ledger cards, sales invoices, and           






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