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he and Mr. Roach worked together, but he estimated that they
jointly performed about 10 installations.
Petitioners maintained two checking accounts with Regions
Bank throughout 1996. Although one account was denominated a
“personal” account and the other a “business” account,
petitioners commingled income from Mr. Sasser’s business between
the two accounts, and they utilized the personal account for most
of their financial transactions. In 1996, petitioners made total
deposits of $29,096 to the personal account and total deposits of
$1,518 to the business account.
In 1996, Mrs. Sasser received wages net of withheld taxes in
the amount of $17,267.
In 1996, petitioners received a refund of Federal income tax
for the taxable year 1995 in the amount of $1,730. The refund
was not deposited in either of petitioners’ checking accounts.
In December 1996, petitioners obtained a cash advance from a
credit card company in the amount of $1,500.
During 1996, Mrs. Sasser deposited amounts received from her
brother in petitioners’ personal checking account. Mrs. Sasser’s
brother, who lived next door to petitioners, was a construction
worker who did not have a checking account, and he was not
financially responsible. Mrs. Sasser then paid certain of her
brother’s bills by issuing checks drawn on petitioner’s personal
checking account. Mrs. Sasser received approximately $300 per
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