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The
Company did not have sufficient technical expertise to address or
establish adequate policies and procedures associated with accounting
matters. In addition, it did not maintain policies and procedures
to
ensure adequate management review of the information supporting the
financial statements.
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The
Company did not have sufficient technical tax expertise to establish
and
maintain adequate policies and procedures associated with the operation
of
certain complex tax structures. As a result, it failed to establish
proper
procedures to ensure the actions required to enable the Company to
realize
the benefits of these structures as previously recognized in its
financial
statements were performed.
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