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disposed of during 1996.
Throughout the period during which Kedd was operating
Richard’s restaurant in Hartford, petitioner maintained the books
and records for that corporation and prepared its payroll using
an Apple computer. At all relevant times, he also maintained the
books and records and prepared the payroll for TRM and Prints
Unlimited.
At all relevant times, petitioner’s activities relating to
the operations of two Richard’s restaurants, an art gallery, and
stock investments took a great deal of his time.
Since Kedd began operating Richard’s restaurant in Hartford
in 1981, TRM began operating Richard’s restaurant in New Castle
in 1987, and Prints Unlimited began operating an art gallery in
1993, petitioner retained an accountant to prepare the S corpora-
tion tax returns, Forms 1120-S, for those S corporations. That
accountant relied on petitioner, who kept the books and records
of those S corporations, to provide him with the information that
he needed to prepare those returns.
Prior to 1985, petitioner prepared tax returns (returns) for
Ms. Mason and himself without using a computer tax software
program (tax software program). Starting in 1985 and at all
relevant times thereafter, petitioner prepared those returns by
using a tax software program. In 1992, a tax software program
that petitioner had been utilizing was no longer usable on his
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