- 5 -
law. Paulan owns real property and leases it to several of the
restaurants operated by Sidal, as well as to other restaurant
operators. Petitioners managed Paulan’s properties. From 1997
through 2000, Paulan operated at a profit.
Other Individuals and Entities Related to Paulan and Sidal
Lovella Ruckriegel (Lovella) and Robert Ruckriegel (Robert)
are petitioners’ parents. Pursuant to the Paulan partnership
agreement, control and management of Paulan were vested in
Lovella. As a practical matter, however, Lovella’s duties
consisted of receiving, depositing, and recording incoming cash
and writing and recording checks on Paulan’s behalf.
Robert and Lovella own the controlling interest in BR
Associates, Inc., which provides financial advice, bookkeeping,
secretarial, and administrative services to Paulan and Sidal.
Larry Freyberger (Freyberger) works for BR Associates, Inc., with
the title of controller, and he maintains Sidal’s general ledger.
His services on behalf of Paulan consist of receiving the check
register from Lovella and computerizing the transactions recorded
therein, using previously assigned account numbers. He and his
staff provide general bookkeeping services for Sidal and
provide a trial balance5 to an outside certified public
accountant (C.P.A.) at yearend.
5 A trial balance (or adjusted trial balance) is a record
taken from the books of account. See Cooper & Ijiri, Kohler’s
Dictionary for Accountants 24, 514 (6th ed. 1983).
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011