James Joseph, Jr. - Page 4




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          paid petitioner’s return preparation fee from the RAL proceeds.             
          The bank issuing the RAL received the refund from respondent.               
          C.   Petitioner’s Records and Returns                                       
               Petitioner did not keep track of his income.  His files and            
          records were disorganized.  He estimated the amount of income to            
          report on his tax returns.  Petitioner reported that he had gross           
          receipts from preparing tax returns of $4,695 for 1992, $13,601             
          for 1993, and $22,895 for 1994.                                             
               Petitioner filed his 1992 return on April 26, 1993, and his            
          1993 return on June 20, 1994.  Respondent did not grant any                 
          extensions of time to petitioner to file those returns.                     
          Petitioner did not pay estimated tax in 1992 or 1993.                       
          D.   Respondent’s Examination and Determination                             
               Respondent’s revenue agent asked petitioner for records of             
          his checking and savings accounts and canceled checks and deposit           
          slips, but he did not give any of those records to the agent.               
          The revenue agent had no records from petitioner.  The revenue              
          agent asked petitioner to complete a personal living expense                
          statement, but petitioner did not do so.                                    
               Respondent’s agent used Internal Revenue Service computer              
          records to identify returns bearing petitioner’s return preparer            
          number.  Respondent’s agent found petitioner’s preparer number on           
          726 returns for 1992, 756 returns for 1993, and 700 returns for             
          1994.  In 1997, respondent’s revenue agent mailed a questionnaire           






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