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gross receipts in the amount of $737,86 .4 Arthur T. Moore (Mr.
Moore), a certified public accountant, prepared petitioner's 1984
return from information supplied by petitioner and sent the
return to petitioner. Petitioner has no original books or
records supporting the figures that appear on the copy of the
1984 return. Petitioner, however, has a work sheet allegedly
prepared in-house showing a trial balance of his business as of
December 30, 1984. Mr. Moore did not know whether the 1984
return that he prepared was filed, and petitioner did not testify
that he filed the return. The record does not contain any
information concerning petitioner's 1981, 1982, 1983, and 1985
tax returns.
Petitioner did not testify as to the date that he filed the
returns for the years at issue. A copy of the 1986 return shows
that petitioner executed that return on September 26, 1992. That
return was prepared by "Greenberg & Jackson, CPA'S" (Greenberg
firm). A copy of the return for 1987 attached to the petition
shows that it was prepared by Mr. Moore and shows a date of
February 20, 1994, whereas a copy of the 1987 return attached to
the stipulation of facts is undated and shows that it was
prepared by "William D. Truax, E.A., Inc." (Truax). A copy of
the 1988 return indicates that it was prepared on August 19,
1992, by Truax. Copies of the 1989 and 1990 returns show that
4 The copy of this return cuts off the last digit on the
right-hand column of the Schedule C.
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