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Id. at 176.
One of petitioners’ Memphis neighbors, Jerrel Walker (Mr.
Walker), testified that petitioner prepared his tax returns
during each of the years at issue. Mr. Walker contacted
petitioner, both at his Memphis residence and in Los Angeles,
during the years at issue. Mr. Walker verified that the room in
petitioners’ home claimed as an office contained a desk and file
cabinets, and the waiting room had a dining room table. Also,
Mr. Walker and petitioners were personal friends, and he visited
petitioners’ home on social occasions.
A business contact of petitioner’s, David Porter (Mr.
Porter), testified that petitioner had prepared his tax returns
for many years and that he had visited petitioners’ Memphis
residence for such purposes. However, Mr. Porter had business
meetings with petitioner at locations outside of petitioners’
home, including, but not limited to, Los Angeles and the Memphis
International Airport during the years at issue. Mr. Porter
frequently contacted petitioner by telephone in both Los Angeles
and Nashville.
In a tax return preparation business, the most important
function is the delivery of the completed return to the taxpayer
for signature and filing. No matter how much preparatory work is
performed, none is of any value unless the completed return is
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