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financial services for a set fee. The partnerships paid
petitioner in accordance with the agreements. The partnerships
deducted the fees on their income tax returns as the cost of
services provided by petitioner.
From 1981 through 1990, John Meeks (Meeks), a certified
accountant, assisted in the preparation of petitioner's
individual income tax returns and Forms 1065 for most of the
partnerships. Petitioner gave Meeks photocopies of returns which
were completed in pencil. Meeks reviewed the photocopies for
mathematical errors and forwarded them to petitioner. Petitioner
typed the corrected information on the returns and Meeks reviewed
this information before petitioner mailed the returns to the IRS.
Meeks did not ask petitioner for documentation verifying the
amounts reflected on any of petitioner's returns.
The record reflects that petitioner received the following
amounts from partnerships which he controlled:
1982
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