7
1976 and for all years relevant here. Kane also prepared
petitioners' amended 1981 return. He was petitioners'
representative in two Internal Revenue Service audits.
Respondent audited Bob Wade Ford’s 1988 and 1989 tax returns
late in 1990 or early in 1991. Kane prepared a schedule of
petitioner's basis in Bob Wade Ford from 1976 to the end of 1993
for that audit.
D. Petitioners' Loans to the Wades
Gail Bohannon and Bob Wade gave promissory notes to
petitioners as follows:
Date Amount
Jan. 21, 1985 $96,954.03
Jan. 30, 1986 5,633.11
Feb. 1, 1986 23,205.00
Feb. 17, 1986 4,600.00
Mar. 14, 1986 4,350.00
Mar. 19, 1986 2,500.00
Apr. 21, 1986 4,000.00
May 7, 1986 6,000.00
May 16, 1986 200,000.00
June 6, 1986 3,860.00
June 11, 1986 500.00
July 1, 1986 4,340.00
July 29, 1986 35,205.00
July 30, 1986 4,400.00
Aug. 29, 1986 11,859.37
Sept. 3, 1986 1,800.00
Sept. 10, 1986 4,415.00
Sept. 27, 1986 148,123.53
Total 561,745.04
E. The Citrus Grove/Dirt Fill Operation
Petitioners reported expenses of $127,985 in 1988 and
$135,824 in 1989 from a dirt fill operation conducted on 112
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