Yu-Yang Wu - Page 3




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          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 to                    






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Last modified: May 25, 2011