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apartment managers' reports, petitioners' canceled checks, and
the bills.
Before these summary sheets, however, were given to the
income tax return preparer, petitioner reduced the figures
reflected thereon for rental income by altering the figures that
were initially reflected on the sheets. Petitioner did not
inform his wife nor the income tax return preparer that he had
reduced the figures on the summary sheets for the rental income.
For 1982 and 1983, the summaries given to the income tax
return preparer did not reflect separate items for repair and
maintenance expenses relating to petitioners' apartment rental
business.
To prepare petitioners’ Federal income tax returns for 1982
and 1983, petitioners’ income tax return preparer used the above
handwritten summaries reflecting the reduced rental income
figures that petitioner had entered thereon. The income tax
return preparer did not perform any accounting for petitioners,
and he did not have access to any books and records relating to
petitioners' apartment rental business.
On Schedule E of their Federal income tax returns for 1982
and 1983, petitioners claimed specific deductions in the
respective amounts of $265,389 and $350,474 for repair and
maintenance expenses relating to their apartment rental business.
Petitioners' 1982 and 1983 joint Federal income tax returns
were filed respectively on April 15, 1983, and April 12, 1984,
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