Ronald A. Mason - Page 4




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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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