- 52 - petitioners' rental income orally from petitioners and from the 1987 summary with respect to their 1987 return. The 1987 summary reflected rental income of $30,000 from the Seabrook property, and Mr. Dennett included that income in petitioners' 1987 return. However, petitioners' rental income for that year is $51,890. Mr. Dennett also included rental income totaling $21,600 and $34,000 in petitioners' 1986 and 1988 Schedules E, respectively. However, petitioners' rental income for those years is $49,894 and $42,380, respectively. It strains credulity that Mr. Dennett would have made errors in all three of petitioners' returns for the years at issue by showing amounts of rental income that understated the rental income that petitioners' received and that were different from the amounts that petitioners provided to him for those years. Petitioners also contend that the amount of income reflected in each of the returns at issue and the complexity of those returns demonstrate that petitioners must have provided complete written materials to Mr. Dennett in order for him to have pre- pared those returns. We disagree. Although petitioners' returns required certain calculations that appear to be complex (e.g., depreciation and passive activity loss limitation), the informa- tion that Mr. Dennett needed to perform those calculations (e.g., the cost of petitioners' depreciable property and rental and other passive activity losses sustained by petitioners) was information that he had to have obtained from petitioners.Page: Previous 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 Next
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