Adnan Al Kaissy - Page 18

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            how the air fare was paid and did not check with petitioner's                              
            "employer" or discuss with petitioner the expenses he was                                  
            entitled to deduct.  She stated in her testimony at trial that                             
            she had no conversation with petitioner when she was preparing                             
            his return with respect to whether he was entitled to deduct                               
            expenses for airline tickets.  She stated that she did not have                            
            such a discussion, because--                                                               
                  these wrestlers were not getting reimbursed all those                                
                  years.  They were not getting reimbursed according to                                
                  what I know.  They were not getting reimbursed. * * *                                
                  these wrestlers always paid their own expenses * * * it                              
                  never occurred to me to ask him that [whether the cost                               
                  of the airline tickets had been included on the Forms                                
                  1099 furnished him by MBWC]. * * * if a salesman came                                
                  to me * * * I would ask him.  They are different than                                
                  wrestlers are, but I would ask a wrestler too, but they                              
                  never did get reimbursed.                                                            

            When this testimony of petitioner's return preparer is considered                          
            in the light of the rest of the evidence in this record, it is                             
            reasonable to infer that petitioner considered that his return                             
            preparer had approved the way in which he was handling his                                 
            deductions for air fare on his return.                                                     
                  The record shows that in an economic sense a portion of the                          
            airline fares was paid by the wrestlers.  The amount a wrestler                            
            got from a show was computed by taking a certain percent (usually                          
            30 to 35 percent) of the gross amount received by the club for                             
            putting the show on, after deductions of television costs, taxes,                          
            and the transportation of wrestlers, where that was paid, and                              

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