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DUI, deposited $33,025 in credit card authorization slips into
DUI’s bank account.
Cash and checks received at the various DUI offices for
legal services rendered were deposited into the DUI bank account
designated for that office.
During 1992 and 1993, Johnson periodically wrote checks,
drawn on the DUI account in Sarasota in favor of DUI or cash, and
mailed the checks to DUI’s Tampa office for deposit by petitioner
or by other DUI personnel into DUI’s account in Tampa (interbank
transfers).
For 1992 and 1993, DUI’s books and records and petitioner’s
personal books and records were incomplete and inadequate.
DUI reported on its 1992 and 1993 S corporation Federal
income tax returns gross receipts of $473,156 and $429,186,
respectively.
On audit, using the bank deposits method, respondent
determined that DUI had gross income not reported on DUI’s 1992
and 1993 tax returns of $8,343 and $18,232, respectively.
Respondent calculated the amount of DUI’s interbank
transfers after meeting with Nick Ligori (Ligori), petitioner’s
accountant. Ligori provided respondent with a record prepared by
Ligori that established interbank transfers of $40,850 for 1992
and $12,356 for 1993, including transfers of funds from DUI’s
account in Sarasota to its account in Tampa. For 1993, Ligori
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Last modified: May 25, 2011