James J. Coyle - Page 9

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          Instead, Mr. Herman used information prepared or provided by                
          Regal’s bookkeeper or Mr. Coyle in preparing Regal’s tax returns.           
          Mr. Herman requested that Regal provide him with documents such             
          as checks, inventory statements on sales tax returns, bank                  
          statements, a listing of accounts receivable and notes payable,             
          and deposit receipts.  He experienced difficulty obtaining the              
          documents and information from Regal, however, and even when he             
          received information, it was often incomplete.  Mr. Herman                  
          prepared certain books and records for Regal, a small portion of            
          which he produced to the Court.                                             
               Mr. Herman also prepared Mr. Coyle’s tax returns for 1992              
          and 1993 using information prepared or provided by Mr. Coyle.               
          Mr. Coyle would provide information in writing or orally.  Mr.              
          Coyle was not clear as to whether he actually provided Mr. Herman           
          with receipts he received from sales of wheels and axles.                   
               On February 2, 1993, Mr. Coyle submitted an offer in                   
          compromise with an attached Form 443-A, Collection Information              
          Statement for Individuals, to respondent, which respondent                  
          rejected.  Mr. Coyle resubmitted the offer in compromise dated              
          December 3, 1993, which respondent accepted on August 3, 1994.              
          As a result, Mr. Coyle compromised taxes due of $32,150.76 for a            
          total payment of $6,000 for the 1986, 1989, 1990, 1991, and 1992            
          tax years.                                                                  

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