Dwight L. McKenna and Beverly S. McKenna - Page 19

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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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