- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011