Theldon and Mary Parrett - Page 4

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          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. Parrett was a construction supervisor, and Mrs.              
          Parrett was a floor supervisor and a dealer at a casino.  They              
          reported combined wages of $88,220 and $82,787, respectively, for           
          1998 and 1999.                                                              
               Prior to the years at issue, petitioners either prepared               
          their Federal income tax returns themselves or had them prepared            
          by a friend.  For the 2 years in question, however, petitioners'            
          returns were prepared by Robin Beltran.  The record does not                
          reflect the circumstances surrounding their employment of Mr.               
          Beltran.2  Mr. Beltran prepared petitioners' returns for 3 years,           
          1998, 1999, and 2000.  For the initial year, 1998, petitioners              
          presented to Mr. Beltran the same type documentation petitioners            
          maintained for the years in which petitioners prepared their own            
          returns.  That documentation appeared to be for charitable                  
          contributions but not for the miscellaneous deductions at issue.            
          Mr. Beltran advised petitioners that such records were not                  
          necessary and could be disregarded because, irrespective of                 

               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.                

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