- 6 - Thereafter, petitioner met Sam Morris (Morris), a Las Vegas accountant, at a conference in Los Angeles, California. In response to questions by Morris, petitioner explained his business and the types of expenses he incurred. Morris offered to review petitioners' returns to see whether petitioner could take advantage of certain deductions. Petitioner checked Morris' references and found nothing unusual. Sometime in 1991, petitioner sent a 30-pound box by Federal Express to Morris' office in Las Vegas, Nevada. Petitioner kept no receipt or list of the documents contained in the box, but he believes the box contained all of his tax records for 1988 through 1991, including credit card statements, bank statements, receipts, copies of prior tax returns, and his daily log for those years. Morris prepared, and petitioners signed and filed, a Form 1040X (the amended return) for taxable year 1989. When Morris presented petitioner with the amended return, petitioner did not review it in depth prior to signing and filing it. Respondent received the amended return on April 3, 1992. On the Schedule C for the computer consulting activity attached to the amended return, petitioner reported gross receipts in the amount of $75,312 and claimed the following expenses: Expense Amount claimed Car and truck $3,390 Depreciation 3,591 Insurance 1,412 Other interest 3,277 Legal/professional 1,301 Rent/lease machinery and equipment 50Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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