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Wilson and Gilmore relied on Stewart for accounting and tax
assistance in organizing G&W, including establishing the
company's record-keeping systems and a profit sharing plan.
Stewart also assisted Gilmore and Wilson in the formation of a
partnership to acquire and manage certain real estate. G&W's
books and records were maintained by Stewart, who typically
prepared the corporation's Federal income tax returns, including
the returns for the years in issue. G&W's returns were reviewed
by Gilmore and Wilson before the returns were filed.
The Hogards became clients of Stewart in the mid-1960's.
Details regarding the nature and extent of their relationship or
the services that Stewart provided to the Hogards are unclear.
It appears that Stewart, or one of his associates, prepared
all of the relevant Federal income tax returns and applications
for tentative refunds involved in these cases; however, we note
that the record contains only unfiled copies of some of these
documents, so our finding on this point is not established. We
also note that Exhibit 3-C, which was attached to the stipulation
of facts, is a copy of a 1981 individual Federal income tax
return for Romine C. Hogard. Unlike the other years in issue, we
do not have a copy of a joint Federal income tax return for the
Hogards for that year. Nevertheless, the notice of deficiency
for the Hogards makes determinations as though they filed a joint
return for that year, and the parties have proceeded accordingly.
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