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Petitioners' Accountants
Since 1971 when petitioner graduated from law school,
he has retained certified public accountants to prepare his
individual income tax returns. From 1977 through the years
at issue, petitioners have retained Mr. Gary Whittington, a
certified public accountant, to prepare their individual
income tax returns and the returns of some of the
businesses with which petitioner was involved.
Petitioners' personal returns for 1978 through the years
in issue were prepared by Mr. Whittington and Ms. Elizabeth
Ruble, whom Mr. Whittington employed. As mentioned above,
Ms. Ruble is a certified public accountant who began
working closely with Ms. Cates soon after Ms. Cates was
employed by petitioner.
The preparation of each of petitioners' individual
returns followed a similar pattern. Typically, Ms. Ruble
would contact Ms. Cates in March or early April to
determine whether petitioners had sufficient information to
file a return for the prior calendar year by April 15th, or
whether it would be necessary to file application for an
extension of the filing deadline. If, as was often the
case, an extension was necessary, Ms. Ruble would work with
Ms. Cates to estimate petitioners' tax liability for the
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Last modified: May 25, 2011