- 21 - 1988 1989 1990 1991 1992 Income: Rental income $168,400 $179,406 $109,185 $221,563 $200,390 Other income 16,148 Total income 168,400 195,554 109,185 221,563 200,390 Expenses: Salaries & wages 31,778 48,627 40,260 40,000 Repairs 87,433 Rents (Hangar) 7,618 12,345 16,208 18,310 17,826 Taxes 18,694 4,561 3,166 3,612 Depreciation 86,502 322,667 194,240 116,583 108,057 Employee benefits 4,408 108 Other expenses 269,890 169,331 374,463 424,697 316,743 Total expenses 364,010 646,656 638,099 603,124 486,238 Net income or (loss)(195,610) (451,102)(528,914)(381,561)(285,848) Accountant’s Role Throughout the years at issue, petitioner utilized the services of Victor DiMaggio, a certified public accountant. Mr. DiMaggio provided consulting services to petitioner with respect to LFI and BAC, prepared LFI’s, BAC’s, BCC’s, and petitioners’ tax returns, and helped LFI’s and BAC’s employees set up and maintain the books and records for those companies. Mr. DiMaggio also advised petitioner individually regarding some tax matters. Petitioner instructed his employees to contact Mr. DiMaggio directly whenever they had any tax-related questions. At some point before he prepared petitioner’s 1989 return, Mr. DiMaggio warned petitioner that LFI and BAC may be activities not engaged in for profit and that, therefore, the losses attributable to those activities may be disallowed under section 183. In addition, in the course of preparing BCC’s tax returns for the years at issue, Mr. DiMaggio estimated that a substantial portion of the amounts billed to BCC by LFI and BAC for 1990, 1991, and 1992 were attributable to petitioner’s personal use ofPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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