- 35 - of income and avoid the payment of taxes. We find petitioners’ explanation implausible. 3. Failure To Provide Return Preparer With Accurate and Necessary Information Petitioners also failed to provide their tax preparer with all the information and records necessary to prepare their 1994 and 1995 individual and corporate income tax returns. Mr. Ling informed Mr. Kong that all income should be reported and all corporate receipts should be deposited into a corporate account. When Mr. Kong provided information to Kim Y. Ling, P.C., to prepare the individual and corporate income tax returns in 1994 and 1995, Mr. Kong failed to inform the tax preparer that a large portion of the corporate receipts had not been deposited into the corporate account. Mr. Kong did not advise Kim Y. Ling, P.C., of additional unreported income until after respondent began his investigation. We believe that Mr. Kong intended to reduce taxes by concealing corporate receipts and by failing to provide this information to his accountant. See Federbush v. Commissioner, 34 T.C. at 750. 4. Maintaining Inadequate Books and Records Sam Kong Fashions failed to maintain adequate books and records and failed to maintain correct records of its gross receipts. Petitioners have failed to offer any records from Sam Kong Fashions to show the number of full- and part-time employees, the hours that these employees worked, or the hourlyPage: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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