Benjamin and Sallie Campfield - Page 11

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               On petitioners' Form 1040 for the taxable year 1984,                   
          petitioners reported other income of $124,000.  Nyden wrote                 
          "COMMISSIONS" next to the entry of $124,000.  On petitioners'               
          Form 1040 for the taxable year 1985, petitioners reported other             
          income of $50,000.  Nyden wrote "COMMISSIONS" next to the entry             
          of $50,000.                                                                 
               Petitioners filed their 1984, 1985, and 1986 Federal income            
          tax returns on October 15, 1985, October 16, 1986, and September            
          10, 1987, respectively.  Respondent issued a statutory notice of            
          deficiency dated October 16, 1992, for petitioners' taxable years           
          1984, 1985, and 1986.                                                       
               Nyden also prepared the Forms 1120 for Arturo's during the             
          years in issue.  Nyden would go to Arturo's or to petitioners'              
          home and pick up bank statements, canceled checks, check stubs,             
          and the day sheets for Arturo's.  Nyden used this information to            
          complete the Forms 1120.                                                    
          Respondent's Investigation                                                  
               Respondent began a criminal investigation of petitioner                
          sometime prior to 1991.  Special Agent Edward J. Burke (Agent               
          Burke) with the IRS criminal investigation division investigated            
          petitioner for the taxable years 1984, 1985, and 1986.                      
               Agent Burke interviewed petitioner, and Kearns represented             
          petitioner during the interview.  During that interview,                    
          petitioner, on the advice of counsel, invoked his rights under              






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