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8. The Return Preparers
G.A. “Al” Piepho prepared ERG’s and NPI’s 1987 returns.
Piepho died on or about October 1, 1989. After Piepho died,
Bradac purchased Piepho’s accounting practice. For the tax years
beginning in or after 1988 through 1994, Bradac generally
prepared the tax returns for ERG, NPI, and each of the
petitioners. However, Jill Toibin, C.P.A. (Toibin), prepared the
Bensons’ 1992 Form 1040.
9. Notices of Deficiency
On October 15, 1997, respondent issued Eric a notice of
deficiency for his tax year 1993. On September 10, 1998,
respondent issued notices of deficiency to Eric, Mark, and Brad
for the 1994 tax year. On September 13, 2000, respondent issued
to the Bensons notices of deficiency for the tax years 1988,
1989, 1990, and 1993. On September 24, 2001, respondent issued
to the Bensons a notice of deficiency for their 1994 tax year.
(a) Examinations
On November 19, 1996, respondent opened an examination of
the Benson’s 1993 return. The examination of the Bensons’ 1993
return related to an ongoing examination of ERG, which
examination commenced on August 23, 1995. On March 11, 1997,
respondent opened an examination of the 1988, 1989, 1990, and
1994 returns of the Bensons.
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