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Petitioners' Income Tax Returns
Mr. Gerald Silverstein, a public accountant, prepared
petitioners' joint individual income tax returns for
taxable years 1976 through 1985. Mr. London annually
provided Mr. Silverstein with the information necessary to
prepare petitioners' individual returns. From time to
time, Mrs. London also delivered to Mr. Silverstein Forms
1099 and other information necessary to prepare the
returns. After Mr. Silverstein prepared each return, he
would give it to Mr. London. Mr. Silverstein signed
petitioners' signatures on their return for 1984. He was
not present when petitioners' returns for 1983 and 1985
were signed.
Mr. Abraham Trugman, a certified public accountant,
prepared the Schedules C, Profit or (Loss) From Business or
Profession, for Mr. London's check-cashing business, M.L.
Associates. Mr. London supplied Mr. Trugman with bank
statements, deposit slips, and machine tapes showing the
weekly check-cashing income of the business. Mr. London
forwarded the Schedules C to Mr. Silverstein for use in
preparing petitioners' joint individual income tax returns.
Mr. Trugman never met Mr. Silverstein.
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