- 3 - not disclose who, if anyone, owned the remaining interests in PAC. PAC was in the business of selling and repairing personal computers and computer parts. Petitioner was in charge of PAC. He made the day-to-day business decisions for PAC, signed its corporate income tax returns, had sole signature authority for PAC’s business checking account, hired and supervised PAC’s bookkeepers and return preparers, and dealt with customers daily by making sales and receiving payments. Petitioner understood that all revenue receipts from the sale of computer equipment and from repairs performed by PAC should be deposited in PAC’s business account. Petitioner also understood that PAC’s accountant was preparing PAC’s income tax returns on the basis of information regarding sales, purchases, and expenses that petitioner provided to him from PAC’s books and records. PAC’s books and records were maintained under petitioner’s supervision and control. Petitioner understood that if he failed to record sales revenues in PAC’s books and records, those revenues would not be reported on PAC’s income tax returns. Petitioner instructed many of PAC’s customers to pay for their purchases or repairs in cash, to leave the payee lines of their checks blank, or to write petitioner’s name on the payee lines of their checks. Petitioner also wrote, or asked PAC’s customers to write, on the memo lines of their checks toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011