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taxpayers' returns or in determining taxpayers' tax liabilities.
During the years at issue, Mrs. Daniel worked as a customer
service manager in the Collections Division in charge of
overseeing other account representatives.
Petitioners are active members of their local religious
community. They also support a missionary church in Jamaica that
operates a basic (elementary) school for children. Petitioners
are friendly with the missionary church's minister and have
attended church functions with the minister and his wife.
In early October 1992, several days of heavy rain caused a
flood that damaged petitioners' property. The flood caused water
damage to a sunk-in family room and a garage located at the rear
of their house. The flood also destroyed several trees in
petitioners' backyard.
Mrs. Daniel ordinarily fills out petitioners' tax returns.
Since she was uncertain as to how to claim a casualty loss
deduction on their 1992 return for the flood damage, she asked
Albert Rabassa, one of her subordinates in the Collections
Division, to assist her.
Mr. Rabassa began his employment with the Internal Revenue
Service (IRS) in September 1990. In 1988 or 1989 (Mr. Rabassa's
testimony was that he was not sure of the date), Mr. Rabassa was
employed at Florida National Bank as a senior vice president. He
was 58 years old and was employed as Division Director of Data
Processing; his salary was $99,000 per year. He also enjoyed
various "perks" and bonuses. The bank was sold in 1988 or 1989
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