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Instead, Mr. Herman used information prepared or provided by
Regal’s bookkeeper or Mr. Coyle in preparing Regal’s tax returns.
Mr. Herman requested that Regal provide him with documents such
as checks, inventory statements on sales tax returns, bank
statements, a listing of accounts receivable and notes payable,
and deposit receipts. He experienced difficulty obtaining the
documents and information from Regal, however, and even when he
received information, it was often incomplete. Mr. Herman
prepared certain books and records for Regal, a small portion of
which he produced to the Court.
Mr. Herman also prepared Mr. Coyle’s tax returns for 1992
and 1993 using information prepared or provided by Mr. Coyle.
Mr. Coyle would provide information in writing or orally. Mr.
Coyle was not clear as to whether he actually provided Mr. Herman
with receipts he received from sales of wheels and axles.
On February 2, 1993, Mr. Coyle submitted an offer in
compromise with an attached Form 443-A, Collection Information
Statement for Individuals, to respondent, which respondent
rejected. Mr. Coyle resubmitted the offer in compromise dated
December 3, 1993, which respondent accepted on August 3, 1994.
As a result, Mr. Coyle compromised taxes due of $32,150.76 for a
total payment of $6,000 for the 1986, 1989, 1990, 1991, and 1992
tax years.
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