- 21 -                                         
               1987         1988         1989                                         
          John Kenny Co.                                                              
          Wages                 $34,876.64   $31,351.34   $31,200.00                  
          Federal tax withheld     4,935.09     4,236.30     4,200.04                 
          State tax withheld         811.42       732.90       803.14                 
          Social Security                                                             
          tax withheld        2,493.68     2,354.49     2,343.12                      
          Douglas Water Co.                                                           
          Wages                  6,500.00     6,750.00     6,500.00                   
          Federal tax withheld       542.00       540.00       520.00                 
          State tax withheld         160.68       166.86       160.68                 
          Social Security                                                             
          tax withheld             464.62       506.98       488.06                   
               After withholding for various taxes, Mr. Morris received               
          during 1987, 1988, and 1989, respectively, (1) net wages (a) from           
          John Kenny Company of $26,636.45, $24,027.65, and $23,853.70 and            
          (b) from Douglas Water Co. of $5,332.70, $5,536.16, and $5,331.26           
          and (2) total net wages from both of those companies of                     
          $31,969.15, $29,563.81, and $29,184.96.                                     
               Petitioner relied on Mr. Morris to prepare the joint returns           
          for the years at issue, had confidence in his ability to prepare            
          those returns properly, and, as far as petitioner knew, Mr.                 
          Morris never received any complaints about the returns that he              
          prepared for others.                                                        
          Criminal Charges of Tax Evasion                                             
          Against Mr. Morris                                                          
               On December 30, 1992, Mr. Morris pleaded guilty to two                 
          counts of tax evasion under 26 U.S.C. section 7201 (1994) for not           
          reporting as income in the joint returns for 1987 and 1988                  
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