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Beginning in 1960, until the time of Mr. Dennett's death in
November 1991, Mr. Dennett's wife, Margaret Dennett (Ms.
Dennett), worked at Mr. Dennett's office. Ms. Dennett's duties
included preparing some less complicated tax returns for Mr.
Dennett's clients, preparing payroll returns, checking and
proofreading typing, entering data into Mr. Dennett's office
computer, and ensuring that written materials that clients
provided to Mr. Dennett's office for use in the preparation of
their tax returns were returned to those clients upon completion
of that return preparation.
At least during the 1980's, Joyce Wildes (Ms. Wildes) also
worked in Mr. Dennett's office and assisted him by preparing tax
returns. During each of the years at issue, Mr. Dennett's office
prepared approximately 300 tax returns.
When a client retained Mr. Dennett for tax return prepara-
tion, Mr. Dennett generally followed one of the following prac-
tices: (1) Mr. Dennett met with the client, asked for and
received information with respect to the client's tax return,10
and prepared a draft tax return while the client waited at Mr.
Dennett's office; (2) Mr. Dennett reviewed written materials that
the client left at his office, asked any questions that he had
based on his review of those written materials by telephoning the
10 It is not clear from the record whether Mr. Dennett's clients
generally provided him with oral and/or written information with
respect to their tax returns.
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