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In connection with Mr. Dennett's preparation of petitioners'
return for each of the years at issue, petitioners visited Mr.
Dennett's office in order to provide him with certain informa-
tion. When Mr. Dennett had finished preparing petitioners'
return for each of those years based on the information that
petitioners provided to him, his office telephoned petitioners to
inform them that their return was ready. Petitioners then went
to his office and were given the return that Mr. Dennett had pre-
pared, as well as a cover sheet, which, inter alia, summarized
the contents of the return, they signed that return, and they
paid Mr. Dennett's bill. Each of petitioners' returns for the
years at issue was thereafter filed. At all relevant times, both
petitioners knew that it would be unlawful to sign a false
return.
Petitioners did not provide Mr. Dennett with complete and
accurate information from which he could have prepared a correct
return for petitioners for each of the years at issue.
Mr. Dennett prepared (1) unaudited projected business
financial statements (unaudited projected business financial
statements) for Design Consultants for 1986 and for White Star
for 1988 that were dated June 26, 1986, and June 23, 1988,
respectively, (2) drafts of two unaudited statements of income
and expenditures for Design Consultants (draft, unaudited state-
ment of income and expenditures), one for 1986 and one for 1987,
and (3) unaudited personal financial statements for petitioners
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