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F. Preparation and Filing of Federal Tax Returns
Petitioners' 1984 and 1985 Federal joint income tax returns
(which are not in issue) were prepared by petitioners' attorney,
George Breschi. The 1984 return (signed by both petitioners)
reported gross income before adjustments of $67,886 and gambling
income of $48,500. The 1985 return (signed by both petitioners)
reported gross income before adjustments of $74,860 and gambling
income of $45,000.
Petitioners' Federal joint income tax returns for 1986 through
1990 were prepared by Mr. Fidati, petitioners' personal and
business accountant during those years. The 1986 return (signed by
both petitioners) reported gross income before adjustments of
$66,195 and listed no gambling income. The 1987 return3 reported
gross income before adjustments of $101,963 and listed no gambling
income. The 1988 return (signed by both petitioners) reported
gross income before adjustments of $106,129 and listed no gambling
income.
The 1989 return (signed by both petitioners and filed on
October 18, 1990, following a filing extension to August 15, 1990),
reported gross income before adjustments of $165,437 and $60,000 of
3 Mrs. Zaban did not sign the original 1987 joint return
when it was filed. The Internal Revenue Service detected the
error and informed petitioners. Mrs. Zaban signed a declaration
on July 8, 1988, indicating that she had reviewed the 1987 joint
return and that it was true, correct, and complete.
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