- 7 - Monterey’s bank statements. At least for 1988, Joseph used an adding machine to prepare adding machine tapes (the adding machine tapes) totaling various periodic expenses, such as expenses for repairs and telephone, which were deducted on the Schedule C for 1988. Entries on the adding machine tapes correspond to the totals of such expenditures on pages of the peg board. For example, on the Schedule C for 1988 there is a deduction for repairs in the amount of $3,991. There is an adding machine tape headed “repairs”, with 17 items, totaling $3,991.28. Column 21 on the check register pages of the peg board is headed “utilities”. The footed amounts for column 21 match, on an item by item basis, all of the items on the adding machine tape. Examination and Investigation In January 1990, respondent began an examination of the Forms 1040. In July 1990, that examination was terminated, so that respondent could commence a criminal investigation of Joseph (the criminal investigation) with respect to his income tax liability for 1987 and 1988. The criminal investigation resulted in charges and a trial, at which, on, August 5, 1997, Joseph was acquitted of all charges. Administrative Summons On January 25, 1991, in connection with the criminal investigation, Special Agent Richard McLaughlin served anPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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