Linda A. Fields - Page 6




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          receipts on the Fieldses’ 1991 Schedule C was too low.  Mr.                 
          Carcasi also told the revenue agent that he had prepared the                
          Fieldses’ 1991 Schedule C without the benefit of any bank deposit           
          slips.                                                                      
          The Fieldses’ 1993 Return                                                   
               In July 1995, after respondent had commenced his examination           
          for 1991, the Fieldses made a joint return of Federal income tax            
          for 1993 by filing a Form 1040, U.S. Individual Income Tax Return           
          (the 1993 return).  The 1993 return was prepared by Mike                    
          Marshall, a certified public accountant engaged by the tax                  
          attorney the Fieldses had hired (in Mr. Carcasi’s stead) to                 
          represent them in connection with respondent’s examination for              
          1991.  On the 1993 return, the Fieldses reported taxable income             
          of approximately $2.8 million and tax of approximately $1.1                 
          million.                                                                    
          Amended Returns                                                             
               In October 1995, the Fieldses amended the initial 1991                 
          return and the initial 1992 return by filing a Form 1040X,                  
          Amended U.S. Individual Income Tax Return, with respect to each             
          such year (the amended 1991 return and the amended 1992 return,             
          respectively). Mr. Marshall prepared both of the amended returns.           
          On the amended 1991 return, the Fieldses reported $487,591 of               
          additional business income from BIC.  On the amended 1992 return,           
          the Fieldses reported $1,123,263 of business income from BIC and            






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