- 3 - Petitioner received Social Security payments of $6,491 in 1992 and $6,664 in 1993.1 He did not report those payments as income on his returns for 1992 and 1993. B. Petitioner’s Return Preparation Business Petitioner has been a self-employed tax return preparer from 1980 through the years in issue. He charged fees ranging from $0 to at least $70 per return in 1992-94. In the years in issue, petitioner generally filed his clients’ returns by transmitting them electronically through banks to respondent. Petitioner filed paper returns for clients whose electronic returns were rejected by respondent. Petitioner included his name and return preparer number on the returns he prepared. Taxpayers claimed refunds on 99 percent of the returns prepared by petitioner. Petitioner arranged loans in anticipation of refunds (refund anticipation loans or RALs) for taxpayers for whom he electronically filed returns. Banks approved refund anticipation loans in the amount of a client’s anticipated refund and advanced that amount to the client, less fees for the bank and petitioner. The banks paid petitioner a $30 fee for each RAL. The bank issuing the RAL also sometimes 1 Respondent determined that $3,246 of those payments is taxable income to petitioner in 1992 and $3,342 is taxable income in 1993.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011