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issuance of a notice of deficiency to petitioners on April 8, 1999.
The adjustments made in this notice are the subject of the present
controversy.
Petitioners petitioned the Court for a redetermination of
respondent’s determinations. The petition was filed on
petitioners’ behalf by Thomas E. Crowe, Esq. Mr. Crowe withdrew as
petitioners’ counsel on July 10, 2002, 2 months before the trial in
this case was scheduled to begin.
With respect to the returns for 1993 and 1994, petitioner
contacted Accufast and was informed that the tax returns for those
years were correct. Petitioner requested that Accufast provide him
with all records, receipts, or other documentation which he could
use to substantiate the expenses claimed on the 1993 and 1994
returns. Accufast, however, could not provide petitioner with the
requested documentation because Accufast did not retain clients’
records after 5 years. Petitioner believed that the deductions
Accufast claimed as reflected on the 1993 and 1994 tax returns were
accurate.
In addition, petitioner contacted J.E. & Assoc. for documents
it had used in preparing the 1995 return. Petitioner testified
that J.E. & Assoc. claimed it had not prepared petitioners’ 1995
return. Petitioner sent a copy of the return to J.E. & Assoc.
(which showed the return signed by a representative of J.E. &
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