- 7 - Robert and Suzette were evicted from their residence in June 1984, and at that time they were unemployed. By November 1984, their only asset was a 1973 Chevrolet automobile, and their only source of funds came from family members. By the end of 1984, petitioners had been informed by Robert that he and Suzette had no money and petitioners had no reason to believe that Robert would be able to repay them. Accountant’s Advice Clyde N. Freeman, a certified public accountant, prepared petitioners’ tax returns from 1983 through 1987. Mrs. Leonard typically reviewed major items in the returns for errors and personally typed the returns. Freeman knew about the transactions with Robert. Petitioners presented all information about the transactions with Robert to Freeman when their 1985 return was being prepared. Freeman advised petitioners that a loss with respect to those transactions should not be claimed, and that he believed if a deduction for the losses incurred were to be taken, the deduction would be disallowed because of the family relationships involved. Petitioners did not claim a loss with respect to their transactions with Robert on their 1983, 1984, or 1985 returns. In April 1989, just before the period of limitations for 1985 was to expire, petitioners filed an amended return for 1985 claiming a $650,000 "embezzlement loss" arising from their transactions with Robert in 1983. The amended return was prepared by Betty White, another accountant, with Freeman’s assistance.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011