Glenn H. and Diane J. Flood - Page 3




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          dealer.  Petitioner recorded most of the gross receipts for FAP             
          by creating invoices; however, he did not create an invoice for             
          every sale.  Petitioner had no other means to determine the                 
          amount of unrecorded receipts.  Petitioner did not deposit all              
          proceeds from sales into his business or personal bank accounts             
          and also accumulated cash at his residence.  Petitioner reported            
          income for FAP on Schedule C, Profit or Loss From Business.  For            
          the years 1991, 1992, and 1993 FAP was petitioner’s primary                 
          source of income.                                                           
          Glenwood                                                                    
               On May 27, 1988, petitioner purchased Glenwood from Glenn              
          Cantrell for $18,643 and initially operated the business as a               
          sole proprietorship.  An employee managed Glenwood until the                
          employee’s death that same year.  Soon after the employee’s                 
          death, petitioner agreed to form a partnership with Sam                     
          Hammontree (Hammontree), who subsequently became petitioner’s               
          brother-in-law.  Hammontree planned to draw cash from his                   
          retirement fund to pay for a one-half partnership interest in               
          Glenwood, but he was unable to obtain the funds.  Instead,                  
          petitioner and Hammontree orally agreed that Hammontree would               
          manage and receive a salary from Glenwood and pay petitioner from           
          Hammontree’s half of the business profits.                                  










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