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Petitioner filed a joint return with Mr. Reynolds for 1984.
After their divorce in 1985, petitioner did not file returns for
1985 through 1990. Nor did she timely file California income tax
returns for those years.
Petitioner employed a part-time bookkeeper to assist her,
inter alia, in maintaining books and records with respect to her
law practice, preparing and filing any required Federal payroll
and similar tax returns, and organizing the return-preparation
information that petitioner's return preparer, Mr. Golemb, needed
to prepare petitioner's Federal income tax returns. Petitioner
hired a new bookkeeper around late 1988 or early 1989. After
that new bookkeeper started working for petitioner, she became
aware that Federal payroll tax returns had not been filed for
three quarters. The new bookkeeper filed those delinquent
returns, and petitioner paid the Federal payroll taxes and
penalties due as a result of such late filing.
Shortly after each of the years at issue, and within
sufficient time for Mr. Golemb to prepare timely petitioner's
return for each such year, petitioner's bookkeeper sent him the
information that he needed to prepare each such return. Mr.
Golemb prepared a return for petitioner for each of the years at
issue from the information that her bookkeeper sent to him. Mr.
Golemb prepared the payment section in petitioner's 1987 return
relating to estimated tax payments from information that
petitioner provided to him.
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