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Section references are to the Internal Revenue Code as
amended. Rule references are to the Tax Court Rules of Practice
and Procedure, unless otherwise specified.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioner
Petitioner resided in Brooklyn, New York, when he filed his
petition. He operated an accounting business known as H. Wapnick
& Sons, in which he charged fees for accounting services,
preparing tax returns, making loans, and cashing checks.
Petitioner’s clients made checks payable to petitioner, H.
Wapnick & Sons, or cash.
Petitioner’s office was in the basement of his home. Steven
Wolfson (Wolfson) worked for petitioner there, as did
petitioner’s sons, John Wapnick and Seth Wapnick. Seth Wapnick
graduated from the Wharton School at the University of
Pennsylvania. Wolfson graduated from college with a bachelor’s
degree in accounting in 1979. He worked for petitioner from 1979
through the years in issue.
Petitioner had about 1,200 corporate clients and a number of
individual clients during the years in issue. He charged each
client $125 per quarter to prepare tax returns. Seth Wapnick
kept records of the accounting, tax return preparation, and
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