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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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