Joseph A. and Sari F. Deihl - Page 10

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          “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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