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financial statements for Joseph and Caroline Enos, 18 Marvel
Street, Taunton. In addition I have enclosed a power of attorney
signed by both individuals.”
The February 15, 1978, letter from Mr. Newell to Mr.
Hillsdale referred to a financial statement accompanying the
February 15, 1978, letter. Petitioners’ balance sheet for their
business shows that petitioners had accounts receivable of
$496,410, and that petitioners subtracted an uncollectible amount
of $393,466, for a total value of $102,944. A note to the
balance sheet states:
NOTE--THE ALLOWANCE FOR UNCOLLECTIBLE ACCOUNTS
REPRESENTS THE AMOUNT DUE FROM METROPOLITAN METALS,
INC. OF HARRISBURG, PENNSYLVANIA. THE OWNER OF THE
BUSINESS SUPPOSEDLY HAS BEEN THROUGH SEVERAL
BANKRUPTCIES. THE BALANCE REPRESENTS AMOUNTS DUE FOR A
PERIOD LONGER THAN 6 MONTHS, AND THE COMPANY HAS SHOWN
A CONTINUED POLICY OF ISSUING CHECKS WHICH SUBSEQUENTLY
ARE RETURNED BY HIS BANK AS “INSUFFICIENT FUNDS”.
PROSPECTS OF COLLECTING THIS [sic] APPEAR SLIM.
Petitioners’ Statement of Financial Condition and Other
Information, dated June 20, 1978, under the heading “Accounts
Receivable”, states:
Account Receivable Book Value Liquidation Value
Trade, at 12/31/77 $496,410 $102,944*
*One Customer owes $393,466, Collection Appears Slim.
Mr. Enos signed the financial statements for the purpose of
settling petitioners’ tax liability with respondent.
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