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completed much of the daily paperwork for petitioner’s
accountant’s monthly visit and calculated each station’s daily
and monthly inventory. She received from petitioner a salary of
approximately $50,000 in 1990.
Osgood has been petitioner’s payroll bookkeeper since 1976.
She reported directly to Haff but usually talked first to Willett
before consulting him.
Beauchesne has worked for petitioner since 1973. During the
subject years, he met Emile each morning to open the office.
Beauchesne also supervised the truck drivers, did light
maintenance at the stations, and supervised some of the employees
at the stations.
Petitioner’s Accountants
Rubin and Goertz are C.P.A.s who are, and for many years
have been, petitioner’s accountants. Goertz oversaw the
preparation of petitioner’s books and records, and he prepared
petitioner’s financial statements and income tax returns. For
these purposes, Goertz traveled to petitioner’s principal place
of business in Lawrence, Massachusetts (Lawrence), once a month.
While there, he met with Haff but never with Emile or Louise.
Rubin is responsible for petitioner’s tax and business
planning. Rubin usually met with petitioner’s board members in
Lawrence 1 day per month, and he usually conferred with them by
telephone three to four times per week. Rubin never recommended
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