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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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