Anthony G. and Shirley A. Olbres - Page 52

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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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