- 7 - and axles from one of Regal’s employees, Mr. Gibson would give cash to the employee and have that employee sign a receipt. Mr. Gibson provided the Court with 13 receipts dated from July to December 1993 indicating that he paid Regal $8,041 for wheels and axles. The additional item of omitted income determined for 1993 as to Mr. Coyle was $2,500 of income from sales of wheels and axles to Mr. Pearce. Petitioner failed to present any evidence as to this adjustment. During the years at issue, Regal employed a bookkeeper to keep its records. The sales manager or the office manager would often make notations in Regal’s books and records concerning sales of mobile homes. In 1992, Regal purchased a computer system to better maintain its bookkeeping records. Either Mr. Coyle or the bookkeeper would prepare the bank deposit slips for deposits made into Regal’s bank accounts. Petitioner, the bookkeeper, or any one of Regal’s employees made deposits into Regal’s bank accounts. Regal did not produce copies of its books and records to respondent or at trial. Regal’s certified public accountant and tax return preparer, Steven D. Herman (Mr. Herman), reviewed Regal’s books and records quarterly because he filed quarterly and annual tax returns for Regal. He did not audit or analyze Regal’s books and records. Mr. Herman did not rely on the original underlying documents when preparing Regal’s returns because they were not available to him.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