Gerald A. Sadler - Page 3




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          Petitioner's Background                                                     
               From 1972 until December 17, 1996, petitioner was a licensed           
          attorney who practiced law in Texas.  As part of his practice,              
          petitioner prepared tax returns and forms for clients including:            
          (1) Forms 1040, U.S. Individual Income Tax Return, (2) Forms W-2,           
          Wage and Tax Statement, (3) Forms W-4, Employee's Withholding               
          Allowance Certificate, (4) Forms 940, Employer's Annual Federal             
          Unemployment (FUTA) Tax Return, and (5) Forms 941, Employer's               
          Quarterly Federal Tax Return.                                               
               Petitioner was admitted to practice before this Court.  On             
          at least two occasions, he represented clients before this Court.           
          Petitioner's Businesses                                                     
               During the years in issue, petitioner was president and the            
          100-percent shareholder of the following corporations:  (1) Jerry           
          Sadler, Attorney at Law, P.C.; (2) the Law Offices of Jerry                 
          Sadler, P.C.; (3) Sixty Eleven Kirby Corp.;2 (4) Jay Ess, P.C.;             
          (5) J.S., P.C. doing business as Jerry Sadler, Attorney at Law,             
          P.C.; and (6) GEE A. ESS, P.C. (altogether, petitioner's                    
          corporations).                                                              
               During the years in issue, petitioner's corporations were              
          having financial problems.  Payroll checks of petitioner's                  
          employees were bouncing.                                                    



               2  This corporation was formerly known as Airtop Heating and           
          Air Conditioning, Inc.                                                      




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