Mary Ann Tobin - Page 6




                                         -6-                                          
          around Ms. Beard's desk.  Petitioner's room also contains                   
          petitioner's bed and a credenza with built-in filing cabinets.              
          She sometimes works in bed, and she usually keeps books, a                  
          computer, and other papers at her bed.                                      
               Petitioner kept her bank statements for each year in a                 
          drawer with that year's tax documents, such as Forms W-2.  At the           
          end of the year, petitioner put her bank statements, canceled               
          checks, receipts for paid bills for the farm, her Forms 1099, and           
          any other tax-related records in a box labeled for that year                
          beside the desk to give to her certified public accountant,                 
          Joseph Richardson (Richardson), to prepare her return.                      
          Richardson is a partner in the Louisville accounting firm of                
          Richardson, Pennington & Skinner (RP&S).  Petitioner also kept              
          records for past years in boxes in her room.  Petitioner filed              
          spiral-bound copies of her tax returns, one per folder, in the              
          credenza.                                                                   
               Ms. Beard kept some of her tax records in the credenza, and            
          stored her bank statements, mortgage information, vehicle                   
          registration, and personal correspondence in petitioner's room.             
          Petitioner and Ms. Beard occasionally handled each other's                  
          records.                                                                    
          D.   Broadmoor Gardens                                                      
               In the mid-1980's, the University of Kentucky and state                
          agricultural officials began promoting alternatives to growing              






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Last modified: May 25, 2011