- 10 -
“And it certainly wasn’t intentional but it was literally
throwing numbers together to try to get the returns, you know,
filed on time.”
At some point during 1998, and apparently in conjunction
with an investigation into whether to take one of his entities
public, Mr. Deihl engaged the C.P.A. firm Donald R. Leo and
Company, Ltd., to review financial materials and tax returns. As
problems came to light, Mr. Goltz was demoted from his position
as CFO; an individual named Pam Roeper was hired to succeed him
in that role; and Mr. Leo was engaged to reconstruct financial
records, to create general ledgers, and to prepare tax returns
based thereon. Mr. Goltz stayed with the companies until late
2000 attempting to provide whatever assistance he could to Mr.
Leo. Between June of 1998 and April of 2000, Mr. Leo prepared
and filed on behalf of petitioners, Mayor, and KareMor amended
returns for 1996 and 1997, and original and (for petitioners
only) amended returns for 1998.
OPINION
I. Preliminary Matters
A. Record Generally
As indicated by the recitation of issues at the outset of
this opinion, these cases principally concern petitioners’
entitlement, through their S corporations, to deductions or
offsets for a wide range of expenditures. The notices of
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