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petitioner's business income receipt books (Rediform books),
notary journal, and copies of client tax returns prepared by
petitioner. The client tax returns prepared by Dixon Tax Returns
included petitioner's name and identification number as the paid
preparer. After the criminal proceedings and after being
reviewed by respondent's revenue agent, John Donovan (Agent
Donovan), the boxes were returned to petitioner.
In January 1996, petitioner was convicted of 14 counts of
violating section 7206(2) for aiding and abetting the filing of
false income tax returns. Petitioner was incarcerated at a
Federal correctional institution in Dublin, California, for 18
months. As a condition of her supervised release from
imprisonment, petitioner was ordered to file her 1990, 1991, and
1992 Federal income tax returns immediately.
Respondent's service center prepared a "Preparer Inventory
Listing" (PIL) of returns which listed all tax returns prepared
by petitioner in 1990 and 1991; a PIL was not available for 1992
because petitioner's records were unavailable. The PIL included
sufficient information to determine whether a particular return
prepared by petitioner was a Form 1040EZ, a Form 1040A (Short
Form), or a Form 1040 (which included a Schedule A or Schedule C)
(Long Form). The PIL also included the name and Social Security
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Last modified: May 25, 2011