- 32 - subject payments to clients, to the Internal Revenue Service, or to State tax authorities in order to resolve "tax problems that was [sic] due to an error or omission made by the Petitioner." According to petitioner: "These [payments] were for tax services that I performed that there was some kind of problem with." According to petitioner, in each case after "negotiations with client(s) and once the Petitioner and the client came to an oral agreement that the Petitioner would pay the tax bill", "the direct payment was made to fully settle the legal dispute between the Petitioner and his client." Petitioner asserts that "he did not carry professional malpractice insurance", and he orally agreed with his clients to make each of the payments "to avoid litigation and to retain customers." Furthermore, according to petitioner, each of the direct payments was made "to resolve a tax problems [sic] that was due to an error or omission made by the petitioner." Petitioner states: "There was no connection between the 'direct payment' and billing", except in the case of the reimbursed payments, discussed below. To prove the nature of the subject direct payments, petitioner relies on his own testimony, copies of canceled checks or other evidence of payment, such as wire transfers, and in several instances, copies of the billsPage: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
Last modified: May 25, 2011