Wayne and Pamela Berry - Page 7




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          $7,960,4 which was petitioners’ total tax liability for 1979.               
          The remaining balance of the unused credits, $5,942, was carried            
          forward to 1983.  On their 1984 Federal income tax return,                  
          petitioners claimed a net operating loss deduction of $492 as a             
          result of their investment in Whitman.                                      
          C.  Kirk Clothier                                                           
               Clothier is a certified public accountant (C.P.A.), and                
          holds a master’s degree in taxation.  His accounting firm is                
          located in Seattle, Washington.  He has practiced accounting                
          since 1971.  Clothier was introduced to petitioner by                       
          petitioner’s brother, who played volleyball with Clothier in                
          college.  In 1973 or 1974, Clothier began assisting petitioners             
          with their personal income tax returns as well as the corporate             
          income tax returns and financial statements of Apex.  Petitioner            
          and Apex continued to employ the services of Clothier until 1997,           
          when petitioner switched to a local accountant for the purpose of           
          convenience.  In petitioner’s words:  “every year it became more            
          difficult to get down * * * [to Seattle]” from Lake Stevens,                
          which is located 45 miles north of Seattle.                                 
               Clothier’s services to petitioners were not limited to the             
          preparation of their income tax returns.  As Apex became more               



               4The discrepancy between the amount carried back to 1979,              
          $8,007, and the amount of the refund, $7,960, is due to the fact            
          that the carryback caused petitioners to lose a child care credit           
          of $47 for 1979.                                                            





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