Adnan Al Kaissy - Page 11

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            regarding his expenses on trips, and Mrs. Baird would merely                               
            record the information as given to her in the ledger.  During the                          
            period 1984 through 1987 the ledgers were kept in the same way by                          
            petitioner's then wife, now Mrs. Beth Andrew McDaniel.                                     
            Petitioner followed the same system of giving information to his                           
            then wife, which she entered in the ledger book record, as he had                          
            followed with Mrs. Baird.                                                                  
                  Prior to moving to Minnesota in 1981, petitioner had H & R                           
            Block prepare his Federal income tax returns.  He had never                                
            prepared his own Federal income tax returns.  Some of the other                            
            wrestlers referred petitioner to Mrs. June Myslajek (Mrs.                                  
            Myslajek), saying that she did the returns of some other                                   
            wrestlers.  Petitioner believed that Mrs. Myslajek had the                                 
            experience necessary to make out a proper Federal income tax                               
            return for him.  When petitioner met with Mrs. Myslajek prior to                           
            the due date of his 1981 return, he handed her the ledger book                             
            record that Mrs. Baird had prepared under his supervision.  He                             
            told Mrs. Myslajek that she could contact the Gagne organization                           
            if she had any questions about his return.  Mrs. Myslajek told                             
            petitioner that she prepared returns for many wrestlers and knew                           
            how to prepare returns for wrestlers.  Petitioner sat with Mrs.                            
            Myslajek while she prepared his return, and when it was                                    
            completed, he signed and filed the return.  This same method of                            

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