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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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Last modified: May 25, 2011