Gerald Dennis Strong - Page 11




                                       - 11 -                                         
          the severity of the investigation and the civil audit in August             
          of 1997, after which she contacted Robert Beatson II (hereinafter           
          sometimes referred to as Beatson), an accountant and attorney.              
          Beatson immediately filed a power of attorney authorizing him to            
          serve as Mary’s representative with respect to the investigation            
          and the audit.                                                              
               Beatson represented to respondent that Mary (1) did not sign           
          the returns, (2) did not authorize petitioner to sign the returns           
          on her behalf, and (3) wanted to file separate returns for 1988             
          through 1991 and for 1994.  Before August of 1997, Mary did not             
          manifest an intention to file a separate return for 1994.                   
          Respondent’s revenue agent, Howard Bell (hereinafter sometimes              
          referred to as Bell), represented to Beatson that Mary could not            
          file separate returns until the civil audit was concluded.                  
               By a letter dated June 2, 1998, Bell informed Beatson that             
          the civil audit was “essentially complete”.  Beatson then                   
          prepared married-filing-separately tax returns for Mary for 1988,           
          1989, 1990, 1991, and 1994.  Beatson did not prepare separate               
          returns for Mary for 1992 and 1993 because respondent (1)                   
          determined that there was no outstanding tax liability for those            
          years, and (2) represented that the filing of separate returns              
          for 1992 and 1993 would be administratively inconvenient.                   
          Beatson believed that Mary’s interests vis-a-vis the statute of             
          limitations as to 1992 and 1993 were adequately protected by the            






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011