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money and tax matters, an income tax preparation service,
representation during audits of their returns, and estate
planning assistance. Petitioner does not know who owns United
Sovereigns.
During relevant years, United Sovereigns provided petitioner
with a workbook that she filled out and returned to the
organization and which United Sovereigns in turn forwarded to a
return preparer to be used in filling out petitioner's income tax
returns. Other than filling out the workbook, petitioner did not
perform any of the computations required to complete her returns.
United Sovereigns sent petitioner's workbooks to Bill Webber, who
prepared petitioner's Federal income tax returns for the years in
issue. Mr. Webber also represented petitioner during the audit
of her returns. Mr. Webber does not contact the taxpayers whose
workbooks are sent to him prior to preparing their returns, and
he accepts the information set forth in those workbooks.
Petitioner did not investigate the qualifications of any of
the persons owning and operating United Sovereigns prior to
enlisting them to prepare her tax returns, nor was she aware of
Bill Webber's credentials, although she had met him.
OPINION
Petitioner's Photography Activity
We first consider whether petitioner's photography activity
was engaged in for profit within the meaning of section 183. The
general rule of section 183(a) disallows deductions attributable
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