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returns contained numerous errors and claims for deductions to
which she clearly was not entitled. Petitioner generally blamed
her tax return preparer for the mistakes. She stated repeatedly
during her testimony that she provided her tax return preparer
with her tax documentation and other requested information, but
that she was not given the opportunity to review her returns
before the tax return preparer filed them electronically. She
testified that she did not know of the inaccuracies in her
returns until they were selected for examination. During the
examination of her returns, petitioner submitted a Form 1040X,
Amended U.S. Individual Income Tax Return for 1999, marked “For
Information Only Do Not Process,” with unsigned draft Forms 1040,
Individual Income Tax Return, marked “Amended” for 1999 and 2000.
None of these amended forms were filed. These draft documents
were prepared by Sherwin Clark (Clark), to whom petitioner gave a
power of attorney to represent her before the Internal Revenue
Service. As explained further herein, these draft returns were
used by petitioner and her representative in their administrative
negotiations with respondent and in explaining concessions.
A. Dependency Exemption Deductions and Child Tax Credits
Petitioner was unmarried during the years in issue and filed
her tax returns as head of household. Petitioner claimed
dependency exemption deductions for her mother and three children
(the children) who were not her biological children. Two of the
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