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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.
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