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received than using only bank records attached to two survey
responses, and because (2) the record shows that petitioner
received an RAL fee for 99 percent (not 100 percent as
respondent’s agent assumed) of the returns he prepared and filed.
1992 1993 1994
Returns prepared1 724 756 700
Return preparer fee $17 $21 2$26
Total estimated preparer $12,308 $15,876 $18,200
fee
99% of returns prepared 717 748 693
RAL fee $30 $30 $30
Total estimated RAL fee $21,510 $22,440 $20,790
Total gross receipts $33,818 $38,316 $38,990
Less gross receipts $4,695 $13,601 $22,895
reported
Unreported income $29,123 $24,715 $16,095
1 A few of the survey responses for taxpayers whose returns
bore petitioner’s preparer number stated that someone other than
petitioner prepared the return. We disregard those statements
because the record contains no other explanation why petitioner’s
preparer number appeared on those returns unless he prepared them.
2 Although the average preparation fee for 1994 was $28, we
treat respondent’s estimate of $26 as a concession.
We conclude that petitioner had unreported income of $29,123
for 1992, $24,715 for 1993, and $16,095 for 1994.3
3 Petitioner contends that it is inappropriate to use
Bureau of Labor statistics to determine his deficiency. We need
not decide petitioner’s contention because respondent’s
determination is not based on Bureau of Labor statistics.
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