Craig E. and Debbie A. Brown - Page 8

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          disallowed the claimed charitable contribution deduction3 and               
          child care credit. Respondent did not process the amended return,           
          and it was not considered at the time respondent prepared the               
          notice of deficiency.                                                       
               Sometime in 1991 or 1992, the Criminal Investigation                   
          Division of the Internal Revenue Service (IRS) began an                     
          investigation of Morris. On March 27, 1992, a search warrant was            
          issued authorizing a search of Morris' office for various items.            
          Pursuant to the search warrant, investigators were authorized to            
          seize, among other things, Federal income tax returns or amended            
          returns for the years 1989, 1990, and 1991 which included                   
          Schedule A itemized deductions or Schedule C business losses;               
          amended Federal income tax returns for 1990, 1991, and 1992; and            
          client lists or other records identifying clients. The search               
          warrant was executed on March 30, 1992. The return on the search            
          warrant reflects that 84 boxes of documents were seized,                    
          including 3 boxes which contained information related to                    
          petitioners. These boxes were identified as "Brown, Craig--Tax              
          records and return", "Craig & Debbie Brown financial records",              
          and "Amended return, Brown". Subsequently, Special Agent Steven             
          Boyd returned to petitioners all of their identified documents              
          which were seized pursuant to the execution of the search                   
          warrant.                                                                    


               3    The remaining itemized deductions were less than the              
          standard deduction, so respondent disallowed them and allowed               
          petitioners the standard deduction.                                         


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