Lee F. Haney, Sr., and Jean C. Haney, a.k.a. Jeanie Haney - Page 20




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          the tax of a shareholder of an S corporation for the                        
          shareholder’s taxable year, the shareholder’s pro rata share of             
          the corporation’s items of income, loss, deduction, or credit               
          must be taken into account.  Sec. 1366.  As the sole shareholder            
          of Flair Enterprises, the adjustments to the company’s ordinary             
          income would flow through to petitioner and be included on                  
          petitioner’s individual income tax returns for the years in                 
          issue.  The evidence establishes that petitioner’s solely owned S           
          corporation received and failed to report taxable income for the            
          years in issue.                                                             
               During the years in issue, Mrs. Haney regularly cashed                 
          checks from noninsurance customers and checks received from                 
          COPART, B&H, and Hudiburg Chevrolet.  Office procedures at Flair            
          Enterprises required that two sets of books be maintained.                  
          Cashed checks were listed in a handwritten notebook, but not                
          posted to the company’s computer system.  Checks from insurance             
          customers were deposited in Flair Enterprises’ bank account, not            
          cashed, and were recorded in the company’s computer system.  Only           
          deposited checks were included as income on the tax returns of              
          Flair Enterprises for the years in issue.  Several of                       
          petitioners’ family members participated in this dual record-               
          keeping process, by which petitioners were able to avoid                    
          reporting substantial amounts of income received by the company.            








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