- 5 - Petitioners’ S corporation, Continuum Health, Inc. (Continuum), exercised daily management functions and operated the business. Petitioners’ wholly owned C corporation, Continue Care Corporation (CCC), processed the business’s payroll. Petitioner Catherine Keil (Ms. Keil), a licensed physical therapist, handled the business’s daily operation and finances. Ms. Keil also dealt with the business’s accountants and lawyers. Petitioner Johann Keil (Mr. Keil) handled the business’s development and public relations. Mr. Keil had no involvement in the business’s daily operation. In or around 1999, respondent audited petitioners’ personal 1993 and 1994 Federal income tax returns and the related returns of Continuum and CCC. Through a referral, Ms. Keil met Montgomery in the summer of 2000, and petitioners and CCC retained him to handle the audits. Ms. Keil was Montgomery’s contact person for petitioners as to this representation, and she informed him at the time of his retention that he could not accept any settlement as to the case without her consideration and approval of it. Until December 15, 2004, Montgomery dealt exclusively with Ms. Keil as to the subject matter of the audits. His only interaction with Mr. Keil before December 15, 2004, was that they spoke with each other on several occasions in October 2004 about an unrelated matter concerning a nonprofit foundation.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011