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Murphy Body Co., AmRuss, and Association Vnedrenie is not in
evidence. An “Addendum to Charter and By-Laws of Vnedrenie-
Murphy” was prepared for petitioner’s signature in his capacity
as chairman of AmRuss.
On December 22, 1994, AmRuss agreed to sell an armored
vehicle to a Russian entity named Bank Baltisky. Petitioner
signed the sales contract as president of AmRuss.
C. Tax Returns for FabuGlass
Sawyer or his employees prepared the Federal corporate
income tax returns for FabuGlass for 1990-93. Petitioner gave
Sawyer information relating to income, expenses, and various
stock transactions to use in preparing the returns. FabuGlass
reported on its returns for 1990-93 that it was an investment
company and that its business activity was investing in financial
securities and real estate.
Petitioner prepared and signed the original 1994 return for
FabuGlass. FabuGlass reported on its 1994 return that its
business activity was investments. Sawyer or his employees
prepared the first amended 1994 return for FabuGlass and added a
net operating loss carryback but did not change other parts of
the return.
FabuGlass reported that its total liabilities exceeded its
assets for the period 1990-94. FabuGlass reported the following
amounts of gross income and deductions for 1990-94:
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