- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011