Maurice D. and Elinor Taylor - Page 10

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             Scilipoti of his criminal conviction relating to his check-kiting                                    
                    Revenue Officer Scilipoti told petitioner and Mr. Mules to                                    
             prepare the delinquent returns from information available and that                                   
             if all the records were not complete, to file amended returns when                                   
             the necessary information became available.                                                          
                    Petitioner provided Mr. Mules with records for preparing                                      
             petitioners' delinquent returns for 1988, 1989, and 1990, which did                                  
             not include records regarding the grocery/convenience store                                          
             business.  Petitioner did not ask Mr. Mules about the tax                                            
             consequences of the check-kiting scheme.  After preparing and                                        
             signing the joint returns, Mr. Mules hand-delivered them to                                          
             petitioner.  Mr. Mules never discussed the preparation of the                                        
             returns with Mrs. Taylor.  Mr. Mules did not expect to prepare                                       
             amended returns for petitioners if and when the grocery/convenience                                  
             store business records were discovered, and petitioner told Mr.                                      
             Mules that he would hand-deliver the original returns to Revenue                                     
             Officer Scilipoti.                                                                                   
                    Rather than delivering the signed returns to Revenue Officer                                  
             Scilipoti, petitioners mailed joint Federal tax returns for 1988,                                    
             1989, and 1990 to the Internal Revenue Service (IRS) Center in                                       
             Philadelphia. The returns were received on January 29, 1992.  The                                    
             1988 return reported gross income before adjustments of $13,298.                                     
             The 1989 return reported gross income before adjustments of $8,842.                                  

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