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although there is nothing in the record that remotely resembles
any formal agreement or arrangement between G&A (or petitioner)
and PSI. Formalities aside, it appears that PSI and petitioner,
through G&A, were involved in a fee or profit splitting
arrangement in connection with the above-described business
activities that petitioner was involved with during the years in
issue.
Petitioners’ 1992 return was filed on May 30, 1995; their
1993 return was filed on July 18, 1995; and their 1994 return was
filed on September 1, 1995. No extension to file had been
requested or granted with respect to any of the years in issue.
Each return was prepared by a professional income tax return
preparer who had prepared petitioners’ Federal income tax returns
for a number of years prior to the years in issue. The return
preparer also prepared the Federal income tax returns of PSI for
the years 1992 through 1994. For each year, petitioner provided
the return preparer with various personal and corporate books and
records. Petitioner also explained various transactions and
business practices involving G&A and PSI to the return preparer.
For each year in issue, petitioners included a Schedule C,
Profit or Loss From Business, on which items of income and
deductions attributable to G&A are reported as follows:
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Last modified: May 25, 2011