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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 bills
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