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After petitioner consented to extend the period of
limitations for the years 1964 to 1968, his returns for those
years resulted in a "no change" letter. A previous audit of
petitioner's income tax return for 1972 resulted in another "no
change" letter.
D. Preparation of Tax Returns
Petitioner employed several different accountants to prepare
his income tax returns during the years at issue. His returns
for the years 1972 through 1976, as well as a first amended
return for 1975 filed on December 20, 1976, were prepared by
Robert E. Giffin. Mr. Giffin relied upon the CTC receipts
journals for the preparation of these returns and was not made
aware of petitioner's bank accounts or his interest in companies
located in other countries. Mr. Giffin did not know at the time
he prepared the returns that petitioner owned any portion of
Diesel Power stock. A second amended return for the year 1975
and an amended return for the year 1976 filed on February 22,
1978, were prepared by Steven Dutton, a C.P.A. On the amended
return for 1976 petitioner reported increased commission income
of $134,378. Mr. Dutton worked for petitioner from September
1977 until June 1980. The returns prepared by Mr. Dutton were
based upon the CTC receipts and disbursements journals. At
times, Mr. Dutton reviewed the substantiation for certain claimed
deductions. Petitioner's 1977 return was also prepared by Mr.
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