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Mr. Sutton as the return preparer. The 1993 joint return identi-
fied Richard J. DiBernardo, C.P.A. (Mr. DiBernardo), as the
return preparer.8 At the time the 1993 joint return was being
prepared, respondent was conducting an examination of certain of
petitioner’s tax returns for years prior to 1993.
On page 1 of the 1991 joint return, petitioner and Ms.
Brodsky reported, inter alia, the following:
Line on Page 1 of Amount
Item of Income or (Loss) the 1991 Return Reported
Wages, salaries, tips, etc. 7 $66,852
Taxable interest income 8a 590
Dividend income 9 642
Taxable refunds of state and 10 1,428
local income taxes
Business income or (loss) 12 20,811
Total pensions and annuities 17a 14,786
Rents, royalties, partnerships, 18 (10,493)
estates, trusts, etc.
Other income2 22 883
1Petitioner and Ms. Brodsky reported on page 1, line 17b, that none of
the reported amount of pensions and annuities was taxable.
2Petitioner and Ms. Brodsky described their “Other income” as an
“INVESTMENT INTEREST ADJUSTMENT”.
In their 1991 joint return, petitioner and Ms. Brodsky reported
“adjusted gross income” of $79,242, “Itemized deductions” of
$56,819, and “Taxable income” of $13,823.
The 1991 joint return included Schedule C, Profit or Loss
From Business (Schedule C). The 1991 Schedule C indicated that
petitioner operated an audio-video sales business under the name
8Mr. DiBernardo first met petitioner in 1995, sometime prior
to May 14, 1995, the date on which respondent received the 1993
joint return in question.
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