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Because Mr. Alfano felt that the Campanas would not recover
their initial investment in CNC, he decided not to treat CNC
distributions as income on the 1991 Federal income tax return.
If petitioner and Mr. Campana later were to recover their
investment, Alfano felt that an amended return could be filed to
change their reporting position. Petitioner did not request Mr.
Alfano to prepare subsequent years' returns.
During the year 1992, petitioner and Mr. Campana received
from CNC distributions of $58,602. None of the distributions was
reported on the joint Federal income tax return for the year.
The return was prepared at "Green Baker and Associates" and
signed by Gail Campana as surviving spouse.
Petitioner's individual returns for 1993, 1994, and 1995
were prepared by Burton Zocks. During the year 1993 petitioner
received from CNC distributions of $104,982. None of the
distributions during 1993 was reported on petitioner's 1993
Federal income tax return. The 1992 joint return, which Mr.
Zocks reviewed before preparing the 1993 return, reported no CNC
income, and petitioner made no mention of CNC to Mr. Zocks at the
time. There was a large increase in petitioner's CNC
distributions beginning in 1993 because she made a large
investment in 1993. As of June of 1993 petitioner and her late
husband had invested $258,578 in 12 CNC contracts.
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