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Petitioner has practiced accounting since 1974 and has
been licensed as a certified public accountant since 1982.
After graduating from college, petitioner was employed by
Mr. A.C. Rahill, a public accountant, from 1974 through
1981. From 1982 through 1987, petitioner was employed by
an oil company, and he performed bookkeeping services for
other clients. In 1987, petitioner entered into the
agreement with Mr. A.C. Rahill that is in issue in this
case, and he began his own accounting practice. During the
years in issue, he engaged in his own accounting practice.
Prior to 1987, Mr. A.C. Rahill practiced public
accounting in the Oklahoma City area. Mr. Rahill’s
clients consisted of individuals and closely held
corporations. He had been retained by some clients to
provide accounting services for as long as 20 years.
Shortly before the subject agreement was executed, the
Criminal Investigation Division of the Internal Revenue
Service seized the records of 55 of Mr. Rahill's clients.
In general, the records that were seized included copies of
Federal income tax returns, ledgers and journals, profit
and loss statements, records of inventory, records of
accounts payable and receivable, computer storage media and
printouts, and papers used in the preparation of various
tax returns. Shortly after Mr. Rahill's death, in October
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