- 6 - “Page 2", of Form 1045, Application for Tentative Refund (the Form 1045 page 2). The Form 1045 page 2 is preprinted with a schedule (Schedule A) on which (pursuant to instructions) is to be computed an NOL. On the Form 1045 page 2, petitioners computed an NOL of $13,336. Petitioners filed their joint Federal income tax return for 1993 (the 1993 return) on October 7, 1996. Dale K. Barker, Jr. Dale K. Barker, Jr., is a certified public accountant, who was retained by petitioners in March 1993. Mr. Barker was retained, among other reasons, to prepare returns for the audit years. Mr. Barker prepared those returns. He also prepared the 1992 and 1993 returns. The Criminal Investigation Rick Raven is employed by the IRS as a Special Agent. His duties include the conduct of criminal investigations. In January 1993, Special Agent Raven began the criminal investigation. He was assisted in the criminal investigation by Dick Stufflebeam, a Revenue Agent employed by the IRS. Special Agent Raven collected information concerning petitioner’s income and expenses for the audit years. He was not concerned with whether any of petitioner’s tax liabilities for any of the years under investigation could be reduced on account of NOL carrybacks, since he believed that NOL carrybacks were not aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011