Paul Arthur Zipp - Page 9

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          effectively stopped practicing as of the end of July 1991.  In              
          preparing petitioner's 1991 Federal income tax return, the                  
          accountant used the Washington State excise tax amounts to                  
          determine gross receipts and petitioner's checks to compute                 
          expenses.  On the Schedule C attached to his 1991 return,                   
          petitioner reported gross receipts of $888,637, no returns or               
          allowances, and $562,348 of total business expenses, resulting in           
          a net profit of $326,289 from his business.                                 
               During 1991, petitioner used currency in the following                 
          amounts to purchase Krugerrands from Clackamas Gold & Silver,               
          Inc., of Clackamas, Oregon, that were reported to the IRS as cash           
          transactions:                                                               
                     Date          Total Purchase       Currency                      
                    3/18/91        $55,387.50          $19,887.50                     
                    3/26/91        54,900.00           19,900.00                      
                    5/31/91        74,000.00           70,000.00                      
               In early 1993, as a result of the reported cash transactions           
          with Clackamas Gold & Silver, the IRS began an audit of                     
          petitioner's 1991 return.  Petitioner requested that the audit be           
          conducted in his accountant's office in Port Angeles, Washington,           
          where the records were located.  In preparation for the audit and           
          to verify the accuracy of the 1991 return, the accountant                   
          constructed a spreadsheet for 1991.  In preparing the                       
          spreadsheet, however, the accountant made errors that resulted in           
          an understatement of gross receipts in excess of almost $500,000.           





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