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Shortly after Mr. Todar notified petitioner of the clinic
break-in and asked him to attempt to duplicate the destroyed
records, petitioner provided Mr. Todar with all of the informa-
tion that he needed to prepare petitioner's 1991 return, except
the contractor receipts and certain other records relating to the
catering activities of his wife during 1991.
Petitioner requested and was granted one extension of time
until August 15, 1993, within which to file his 1992 return.
Petitioner did not file returns for the taxable years 1991
and 1992 prior to the issuance of the notice of deficiency
(notice) on June 30, 1995. On September 28, 1995, and September
29, 1995, respectively, respondent received Forms 1040 (U.S.
Individual Income Tax Returns) for taxable years 1991 and 1992
that were signed by petitioner and his wife as the taxpayers and
by Mr. Todar as the return preparer.3
At least as late as the summer of 1996, petitioner had
available original records relating to certain deductions claimed
in his 1991 and 1992 returns with respect to his wife's catering
activities. Those original records were misplaced by petitioner
and/or his wife sometime during and/or after the summer of 1996.
During 1996, petitioner produced copies from originals of
American Express and similar monthly statements and receipts that
were relevant to his 1991 and 1992 returns.
3 Petitioner's wife is not a petitioner in this case.
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