- 8 - tax return.10 Mr. Lopez testified that whatever records relating to petitioners that were in Mr. Hunt’s office were left there following his death. He also testified that Mr. Assaad’s records were returned to him as far as he knew and that he does not withhold records in his practice “Even if they don’t pay you.” Mr. Lopez also represented petitioners in the audit of their 1992 tax return. He testified that he experienced difficulty assembling petitioners’ records for substantiation of expenses and other costs, including interest, in part because of Mr. Hunt’s death and in part because of Mr. Assaad’s lack of cooperation. In 1993, petitioners purchased, and began to rent out, property known as St. Rose Manor. Petitioners overstated depreciation deductions with respect to St. Rose Manor by at least $148,747 for 1993, $324,033 for 1994, $324,033 for 1995, and $324,033 for 1996, a total of $1,120,846 over the 4-year period. Petitioners’ overstatement of the depreciation deductions in 1993, 1994, 1995, and 1996, when corrected, reduces the amount of the NOL carryforward available for 1996 and 1997. 10Mr. Hunt continued to work with Mr. Lopez, and he handled all the clients he previously serviced. Mr. Lopez testified that he thought Mr. Hunt was handling petitioners’ returns when he died, but he could not be certain. Mr. Lopez signed petitioners’ return for the 1992 taxable year; however, he was unsure whether he or Mr. Hunt prepared that return. Mr. Hunt and Mr. Lopez did not prepare any of petitioners’ returns for years after the 1992 taxable year.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011