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Financial Statements, Tax Returns, Audits, Notices of Deficiency
Berger is a Certified Public Account and a partner in the
accounting firm of Grant Thornton;18 he also has a J.D. degree
from the University of Maryland School of Law. Petitioner
approached Berger to prepare tax returns for the Sley
Corporations for 1980. Berger continued to prepare or supervise
the preparation of such tax returns for the years through 1986.
Berger also prepared or supervised the preparation of compilation
financial statements and made or supervised the making of
dividend calculations to avoid the personal holding company tax
for the Sley Corporations. Berger prepared or supervised the
preparation of petitioner’s and Betsy’s joint tax returns for
1980 through 1987, and petitioner’s individual tax returns for
1988 through 1991. During the years in issue, Berger or those he
supervised came into the Sley Corporations’ offices in February
to prepare the corporate tax returns and the compilation
financial statements, and in November or December to calculate
the dividends needed to avoid the personal holding company tax.
18 When Berger was first engaged to prepare tax returns
for petitioner and Betsy, and for the Sley Corporations, he was
with the accounting firm of Fox and Co. In 1985, Fox and Co.
merged with Alexander Grant, and was known under the latter name
for about 1 year. Thereafter, Berger’s accounting firm was known
as Grant Thornton.
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