Robert M. Johnson and Janna D. Begole, f.k.a. Janna D. Johnson - Page 4




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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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