- 2 - FINDINGS OF FACT In 1968, petitioner began operating McGowan Construction Company, Inc. (the Company), an S corporation. Petitioner is the president and sole shareholder of the Company. In 1987, petitioner married Bonnie Cason, owner and operator of Bonnie’s Sportswear, a wholesale garment manufacturing business. Soon after they were married, petitioner hired Leonard Kisalus, Ms. Cason’s accountant, to set up the Company’s accounting and payroll records and prepare tax returns. Mr. Kisalus prepared the Company’s 1987 through 1993 returns and petitioner’s 1985 through 1993 returns. In 1990, petitioner purchased a computer for the Company, and Mr. Kisalus installed, on the computer, an accounting software program to record general ledger, payroll, invoice, and accounts receivable information. Petitioner’s secretaries did not have any previous bookkeeping experience, but Mr. Kisalus trained them to manage the Company’s bookkeeping responsibilities. Each year petitioner and his secretaries maintained a handwritten ledger to record all work performed, invoices prepared, and customer checks received. The secretaries opened the Company’s mail and collected customer checks. They would match each check with its corresponding invoice and record, inPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011