- 15 - account to determine bank charges deducted on the Schedules C. Joseph had in his possession, and used, source documents that, we assume, accurately recorded Monterey’s income and expenses. The gross discrepancies between entries on the Schedules C and the amended Schedules C convince us that Joseph did not make inadvertent mistakes in completing the Schedules C. We infer from the ready availability to Joseph of accurate information, which he failed to use, a willful attempt by him to avoid his obligation correctly to state his net income from Monterey. 4. Withdrawals of Funds From Monterey On the amended Schedules C, petitioners reported net profits from Monterey of $94,823 and $69,394 for 1987 and 1988, respectively. When the noncash expense of depreciation shown on the amended Schedules C is added to such net profits, the resulting amounts are $112,492 and $79,804, for 1987 and 1988, respectively. Those amounts coincide with the yearly totals of amounts withdrawn monthly by Joseph from Monterey’s bank account and deposited into interest bearing accounts in his own name. We consider such transfers to be some evidence that Joseph attempted to conceal Monterey’s income, albeit, ineptly. More importantly, we consider such transfers evidence that Joseph knew very well, not only on a yearly, but on a monthly, basis what Monterey’s profits were. Moreover, on the Schedules C, Joseph reported net profits from Monterey of $14,609 and $14,616, for 1987 and 1988,Page: 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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