Haralampos Katerelos and Irene Katerelos - Page 27

                                                 - 27 -                                                   

            Tax Returns                                                                                   
                  Petitioners filed returns for the years 1987 through 1989                               
            that were prepared by Mr. Berlat.27  In those returns, petition-                              
            ers reported gross receipts and net profit of NDV and total gross                             
            income, as follows:                                                                           
                  Gross Receipts    Net Profit                                                            
                  Year        of NDV          of NDV      Total Gross Income                              
                  1987      $323,509         $12,584           $21,094                                    
                  1988       323,037          10,378             8,862                                    
                  1989       350,540          20,262            20,372                                    
                  During 1990, petitioners filed amended returns for each of                              
            the years 1987 through 1989 that were prepared by petitioners'                                
            accountant, Mr. Bailey, a certified public accountant (C.P.A.)                                
            whom petitioners hired as their accountant during respondent's                                
            examination of their returns for 1987 through 1989 because Mr.                                
            Berlat was not a C.P.A.  Petitioners indicated in each of those                               
            amended returns that they had additional gross receipts of $5,200                             
            attributable to "Cash - Register".  Mr. Bailey prepared the                                   
            amended returns for the years 1987 through 1989 after he had                                  
            advised Mr. Katerelos that Mr. Phielix had informed him that                                  
            petitioners had underreported the gross receipts of NDV for those                             
            years.                                                                                        
                  Mr. Bailey prepared petitioners' returns for 1990, 1991,                                


            27  Both parties acknowledge that Mr. Berlat made certain errors                              
            in preparing petitioners' returns for the years 1987 through                                  
            1989.  However, neither party has suggested that those errors                                 
            should affect our findings or conclusions herein.                                             




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