- 3 - for 1998 and 1999 and the disallowed gambling losses for 1999, and (2) whether petitioners are liable for the 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. Lavigne was employed by a construction company, and Mrs. Lavigne was employed by Intel Corp. They reported combined wages of $70,996 and $83,088, respectively, for 1998 and 1999. For the 2 years in question, petitioners' income tax returns were prepared by a return preparer, Robin Beltran. The record does not reflect the circumstances surrounding how petitioners engaged Mr. Beltran.2 Mr. Beltran advised petitioners that records were not necessary to substantiate deductions claimed on their returns, and such records could be disregarded because, irrespective of records, a taxpayer, under the law, was "allowed" deductions for such expenses pursuant to a "formula" based on the income the taxpayer earned. The deductions disallowed by respondent on petitioners' tax returns consisted of the following: 2 The Court notes that this case is one of numerous cases heard by the Court involving tax returns prepared by Mr. Beltran, which essentially involve the same deductions at issue here.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011