- 22 - into personal accounts, or took for personal use, additional corporate funds totaling $85,688 in 1988.14 Petitioner reported no dividend income on his 1988 return from any of his corporations, and the total reported as wages or salary was $37,500. Northwest Audit Northwest commenced an audit of petitioner’s corporations’ consolidator activities on March 1, 1988. Petitioner retained an attorney, Sheldon Belofsky (Belofsky), to represent him and his corporations in the matter of Northwest’s audit of their consolidator activities. Northwest’s audit of petitioner’s corporations’ consolidator activities revealed large “round number” withdrawals from corporate accounts going into various brokerage firm accounts. The brokerage account statements were not kept at petitioner’s corporations’ offices, and Northwest had trouble obtaining copies of the statements from petitioner or from the brokerage firms. During the course of Northwest’s audit of petitioner’s corporations’ consolidator activities, petitioner refused to give Northwest records of receipts from ticket sales to subagents. Petitioner also refused to give Northwest’s auditors personal 14 This $85,688 does not form any part of the $986,856 in funds at issue in this case that respondent asserts is taxable income of petitioner in 1988.Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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