-62- appropriate client accounts. TACI issued annual tax statements and reports to its clients and the Internal Revenue Service on the interest income earned by each client on that client’s funds in the TACI Special E Account and the TACI Special Account. Kanter, as a client of TACI, had funds of his own in both the TACI Special E Account and the TACI Special Account. TACI, as part of its services and acting on Kanter’s behalf, paid some of Kanter’s business and personal expenses out of Kanter’s funds in these accounts. All checks issued by TACI on behalf of a client were debited against the balance such client had in the accounts. If a client had a negative balance in the accounts, that debit amount was considered an indebtedness by the client to TACI. Any positive balance a client had in the accounts was considered money belonging and owed to said client. Included among the services provided by TACI were bookkeeping services for its clients. This included keeping books and records for clients and the preparation of individual income tax returns. TACI prepared Kanter’s income tax returns for all or some of the years at issue. TACI’s offices were located either at the law firm offices of Kanter or in close proximity thereto. Meyers, who was president of TACI, directed the staff and employees of TACI until 1985. Linda Gallenberger (Gallenberger), a C.P.A., became vice president of TACI in 1982 and worked underPage: Previous 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 Next
Last modified: May 25, 2011