- 4 - 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 questionnairePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011