- 9 - C. Mr. Aulisio testified that it was common practice in the accounting industry, in order to deal with Form 1099 amounts misreported to the IRS by third parties, to “make full disclosure by putting the exact same number in and out.” Aside from the questionable validity of this statement, we find it noteworthy that Mr. Aulisio did more than just report and subtract the same numerical figure. He affirmatively labeled the cost of goods sold “PROJECT COSTS”, a term which connotes active operations to a far greater extent than it discloses the alleged situation of inactivity. Webster’s defines “disclose” as “to expose to view” and “to make known: open up to general knowledge * * *; esp: to reveal in words (something that is secret or not generally known): DIVULGE”. Webster’s Third New International Dictionary 645 (1976). Accordingly, we take issue with petitioners’ and Mr. Aulisio’s characterization of the Schedule C reporting as a form of disclosure to the IRS. To report that a particular entity earned gross receipts, incurred project costs and business expenses, and operated at a loss, all with the material participation of its proprietor, hardly exposes, makes known, reveals, or divulges that the entity was inactive, that payments were misreported by third parties, and that the income shown on the Schedule C was actually that of a corporation. If the true intent of petitioners and Mr. Aulisio had been to disclose thePage: 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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