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After Mr. Bruno reviewed and signed the 1987 and 1988
returns, he met with petitioner, and they reviewed the completed
returns together, including the Schedules C for the medical
practice. Petitioner never indicated that there was an error on
the 1987 and 1988 income tax returns, particularly with respect
to the amounts reported as income on the medical business
Schedules C.
Bruno and Tervalon also prepared petitioners' income tax
returns for 1989 and 1990. For these years, petitioner did not
furnish one lump-sum figure to Mr. Bruno or Ms. Walter. Instead,
he submitted copies of the checks he had received as income from
the various personal injury attorneys.
Internal Revenue Service's Civil Examination
Susan Davis was a revenue agent employed by the Internal
Revenue Service from October 1987, through May 1994. She had an
accounting degree and had also received extensive training
throughout the course of her employment with the Service.
In October 1989, Ms. Davis was assigned to conduct an
examination of petitioners' 1987 Federal income tax return. She
initially contacted petitioner by telephone on October 5, 1989,
and advised him that his and his wife's 1987 return had been
selected for examination. When Ms. Davis asked that an
appointment be scheduled, petitioner told her that she would have
to contact his certified public accountant, Mr. Bruno. Since no
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