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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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