Kyl Christians - Page 6

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          Layland, and she did not find it unusual that petitioner’s father           
          handled the tax matters because that type of situation occurred             
          with other clients.                                                         
               Ms. Layland was often frustrated by the inadequate and                 
          inaccurate tax preparation records petitioner’s father submitted            
          to her.  For example, the cashflow statement for K&L Exteriors              
          for the taxable year 1993 reflected gross receipts of $160,397,             
          while the Forms 1099 filed by clients of the business reflected a           
          lesser amount ($111,516).  Through communications with                      
          petitioner’s father, Ms. Layland came to realize that the                   
          cashflow statement figure was incorrect.  Accordingly, she                  
          reported the amount reflected on the Forms 1099.  Petitioner’s              
          father also commingled petitioner’s personal and business                   
          expenses, which Ms. Layland attempted to distinguish and                    
          separate.  Ms. Layland did not contact petitioner about any of              
          these matters.  She dealt exclusively with petitioner’s father,             
          who resolved these matters to Ms. Layland’s satisfaction.  On one           
          occasion, Ms. Layland questioned petitioner’s father about a loss           
          on petitioner’s 1993 Schedule C, Profit or Loss From Business.              
          Petitioner’s father responded with new figures which reflected a            
          small profit.                                                               
               For taxable years 1993 and 1994, Ms. Layland also prepared             
          Four Square’s corporate returns for petitioner.  Because Four               
          Square was incorporated solely for K&L Exteriors’ payroll                   






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