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At trial, petitioner conceded the deficiencies, challenging
only the penalties under section 6662(a). In addition to
considering that issue, the Court also considers the
applicability of section 6673(a) to the facts of this case.
Petitioner was gainfully employed for the 2 years at issue
as a paramedic firefighter for one of the counties in New Mexico.
Prior to the years at issue, petitioner prepared his own
Federal income tax returns. For the 2 years in question, someone
recommended that petitioner employ a return preparer, Robin
Beltran. The individual who recommended Mr. Beltran represented
that Mr. Beltran was a "great guy", who was a "CPA", and "really
knows his stuff, is willing to show you the stuff in the tax laws
that show you all the loopholes, and he can certainly save you a
lot of money." Petitioner arranged to engage the services of Mr.
Beltran for his 1998 Federal income tax returns and for 2 years
thereafter. For the initial year, 1998, petitioner presented to
Mr. Beltran the same type documentation petitioner maintained for
the years in which petitioner prepared his own returns. That
documentation appeared to be for charitable contributions and
employee expenses. Mr. Beltran advised petitioner that such
records were not necessary because, irrespective of records, a
taxpayer, under the law, was "allowed" certain amounts as
deductions for such expenses.
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