- 15 - rejected tax protester arguments of this sort. See, e.g., United States v. Hanson, supra at 945; United States v. Studley, supra at 937. Petitioner also conducted a tax return preparation and tax counseling business from 1984 through 1986. Petitioner advised his clients to file Federal income tax returns claiming the same foreign earned income exclusion that petitioner claimed on his returns. None of petitioner's clients actually worked or resided outside the United States at any time during 1984, 1985, or 1986. Petitioner received fees of $1,800 in 1984, $6,190 in 1985, and $12,790 in 1986.5 Petitioner failed to report these fees as income on his 1984 and 1985 income tax returns, and he has not yet filed a return for 1986. When interviewed by IRS special agents on April 15, 1987, petitioner stated that he had never received payment from anyone in exchange for his tax return preparation and counseling services. Petitioner also informed the agents that he had earned no income in 1986 and was not required to file a return for the 5In request 15, respondent lists the individuals who paid petitioner for his tax return preparation and tax counseling services plus the amount and year of payment. Request 15 asserts that Barbara Gibson paid petitioner $2,108 in 1985. In request 38, respondent attached a copy of Barbara Gibson's canceled check, which is dated Mar. 21, 1986, and payable to petitioner in the amount of $2,108. We, therefore, find that petitioner received this amount from Barbara Gibson in 1986 rather than 1985. With this adjustment, the amounts listed in request 15 correspond to the amount of tax return preparation fees listed in the notices of deficiency for 1984, 1985, and 1986.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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