Padgett Coventry Price - Page 12

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          Preparation of Petitioner’s Tax Returns                                     
               Mr. Reiter’s office prepared petitioner’s tax returns for              
          the years in issue.  This included preparing the Schedule C                 
          related to the law firm.  Mr. Reiter did not reconcile any                  
          personal accounts of petitioner or Mr. Ludlow in order to prepare           
          these returns.  Other than yearend statements showing the total             
          interest or dividend income earned during the year, Mr. Reiter              
          and his staff received no records regarding petitioner’s Merrill            
          Lynch accounts or any other personal accounts.                              
               Unaware of the income petitioner diverted to her Merrill               
          Lynch account, Mr. Reiter and his staff did not include it in any           
          of the monthly financial statements, the annual income                      
          statements, or the income tax returns that Mr. Reiter’s office              
          prepared for petitioner and the law firm.                                   
          Audit of Petitioner                                                         
               In November or December 1991, Revenue Agent Francisco                  
          Rangel began a civil audit of petitioner and Mr. Ludlow’s 1988              
          return.  On December 11, 1991, Mr. Rangel conducted his initial             
          interview at the law firm.  Pursuant to a power of attorney, Mr.            
          Reiter represented petitioner and Mr. Ludlow at the meeting.  Mr.           
          Ludlow attended the meeting, but petitioner did not.                        
               Mr. Rangel asked about the law firm’s business bank                    
          accounts, and he was informed that the law firm had two accounts:           
          The general operating account and the client trust account.                 






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