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number of the taxpayer, the type of form prepared, and the amount
of tax owed. The PIL matched the actual copies of client tax
returns which were seized from petitioner's business.
During 1990, petitioner prepared at least 1,640 Short Forms
and at least 341 Long Forms. During 1991, petitioner prepared at
least 2,191 Short Forms and at least 574 Long Forms, a 40-percent
increase in returns prepared. During 1992, petitioner prepared
more than 3,000 tax returns.
During 1990 and 1991, petitioner generally charged $35 for
the preparation of a Short Form and $75 for a Long Form. During
1992, petitioner generally charged $37 for the preparation of a
Short Form and $78 for a Long Form.
Petitioner's notary journal, which covers the period from
December 22, 1989 to August 9, 1990,1 includes the amount of the
fees paid for petitioner's notary services. The notary fees from
January 1 through June 30, 1990, totaled $2,119.
Petitioner's Rediform books were incomplete; they did not
include records for all of the months of 1990, 1991, and 1992.
Petitioner's Rediform books for 1990 include:
1It should be noted that the Stipulation of Facts states
petitioner's notary journal covers the period from Dec. 22, 1989
to July 20, 1990; however, the actual notary journal covers the
period from Dec. 22, 1989 to Aug. 9, 1990.
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