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transaction statement. Actually, respondent spent
only two hours to put the numbers into the 1040
forms (See Exhibit A), but, hold the progress of
checking the taxable years of 1992 and 1993.
Because respondent knowing that petitioner lost
the main job in 1992 and started to import the
different small quantities of samples of audio
devices from April of 1992. Respondent deliber-
ately hold the progress of reviewing the expenses
of start-up business, which was about two weeks
from Feb. 8, 1999. (Deadline to turn in the paper
to the court). The petitioners hired the attorney
to continue to review and prepare the 1040 form
and schedule C which estimated only need four
hours required, but, not successful and on Feb.
6th, 1999, petitioners being told that counsel
could do it at the second phase; First phase he
did not care about what respondent did. This was
the main reason the petitioner had the motion to
withdraw the counsel.
* * * * * * *
17) The legal counsel was hired to make the progress
of reviewing the COGs of 1992, 1993 and few ex-
penses items which respondent deliberately hold or
partially report in his stipulation report. Dur-
ing the time of hiring, not only the counsel was
late in the meeting called by the judge, but, he
did not make any progress report to petitioners
until Feb. 6th, 1999 (Two days away from the dead-
line set by the court); Besides, the petitioner
(spouse) had the operation of the chest and under
daily radiation treatment of cancer disease; Under
such mentally pressure, Robert forced the peti-
tioners to sign the incompletely stipulation re-
port by saying he can fix it at the second phase.
As the Fraud is an act; only if the professional
made it, later can be caught what did the respon-
dent make. During the stage of professional’s
intention to design the scheme, it was hard to get
the evidence. As Fraud is an act using profes-
sional knowledge to take advantage of the non-
professionals by treating the taxpayer unfairly,
differently or not just. As people say that non-
professionals might use tangible weapons to rob
the bank to get money illegally; But, profession-
als can use intangible way (their knowledge to
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