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adjustments for the disallowed dependency exemption, the taxes,
and the interest.
The issues for decision are: (1) Whether petitioners are
entitled to charitable contribution deductions, unreimbursed
employee expenses, and tax preparation fees for the 2 years at
issue, and (2) whether petitioners are liable for the accuracy-
related penalties under section 6662(a). In addition, the Court
considers the applicability of section 6673(a) to the facts of
this case.
Petitioners were both employed during the 2 years in
question. Mr. Albach was employed by a medical laboratory as a
courier and facility and securities manager, and Mrs. Albach was
a blackjack dealer at a casino. They reported combined wages of
$52,797 and $85,803, respectively, for 1998 and 1999.
For prior years, Mr. Albach (petitioner) prepared
petitioners' Federal income tax returns. Petitioner was in the
military and had no difficulty preparing their returns. In
December 1997, petitioner retired from the military and took on
private employment. With the military pension he was receiving,
along with the wages he and his wife were earning, their combined
income during 1998 increased considerably from their income in
prior years. Nevertheless, as he had done in prior years,
petitioner prepared their joint return for 1998, which was filed.
Thereafter, petitioner began having second thoughts about the
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