Kyle L. and Carol B.Thornton - Page 7




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               credible in his explanation of what * * * [another taxpayer            
               before the Court] called a loophole.                                   
                    THE COURT: But did you question what sort of a loophole           
               would that be, because you're acknowledging that the amounts           
               that you really paid for –– gave to charity were laughable             
               amounts compared to what --                                            
                    MR. THORNTON: Absolutely.                                         
                    THE COURT:  —-he put on the return for you?                       
                    MR. THORNTON: Again, he was simply very, very credible            
               in the way he would explain and the way he would assure, and           
               this is a perfectly allowable, perfectly acceptable amount             
               for our level of income.                                               
                    THE COURT: Did you ever go to some other professional             
               to verify that --                                                      
                    MR. THORNTON: No sir.                                             
               *       *       *       *       *       *       *                      
                    MR. THORNTON: No sir.  Now, and that's –- the term if             
               it's too good to be true, it is.  Compared to what?                    
               Certainly it was much better compared to my own tax                    
               preparation, but this was the first professional I've been             
               to, and --                                                             
                    THE COURT: Anybody can put numbers down.                          
                    MR. THORNTON: I understand that now, sir.  Yes, sir.              

               When petitioners later received notices from respondent that           
          their returns for 1999 and 2000 would be audited, Mr. Beltran               
          advised petitioners to ignore such notices and not meet with                











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