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petitioner's "share" of the margin amount; and (e) the amount
"reinvested" (uniformly it was the amount of the original
investment).
The 1991 Federal income tax return of petitioner and Mr.
Campana was prepared by Joseph Alfano. Mr. Alfano was an
enrolled agent and a self-employed business consultant. At some
point during the return preparation phase, before Mr. Alfano
asked for documentation for items on the return, petitioner
brought up the CNC "investment". She mentioned CNC and showed
him a check. She told him where the check came from and
described the investment. Mr. Alfano advised petitioner that CNC
was not "a normal type of investment".
Petitioner and Mr. Alfano talked about the taxability of the
CNC distributions. He asked petitioner if the distributions she
had received from CNC exceeded the amount of her investment and
she said "no". Mr. Alfano advised her that he did not think that
the transaction was concluded. He told petitioner that he did
not believe that she would get her "invested" money back and
suggested that she try to have it returned to her. Some 4 or 5
months after the initial interview, but before preparing the 1991
return, Mr. Alfano asked if she ever got her money back and she
said "no". She may also have shown him an additional check at
that time.
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