-5-
to attach copies of the closing agreements to their respective
returns. No petitioner attached a copy of his or her closing
agreement to the return for any of the relevant years.
Mr. and Mrs. Hargrove did not retain the services of a
preparer to assist them in filing their returns for 2000 and
2001. Mr. and Mrs. Hargrove did not seek advice from any
accountant, attorney, or other tax professional with respect to
their exclusions of income under sections 912 and 119. Mr. and
Mrs. Hargrove reported they owed tax of $4,719 for 2000 and
$4,123 for 2001.5
Mr. and Mrs. Breeding filed their original returns for 1998
and 1999 without the assistance of a preparer. They then
retained Bob Ross, a certified public accountant located in
California, on the advice of coworkers at the defense facility.
Mr. Ross filed amended returns for 1998 and 1999 on behalf of Mr.
and Mrs. Breeding excluding income under sections 119 and 912.
Mr. and Mrs. Breeding’s original returns for 2000 and 2001,
prepared with the assistance of Mr. Ross, also excluded income
under sections 119 and 912. Mr. and Mrs. Breeding reported they
owed tax of $22,235 for 2000 and $23,169 for 2001.6
Respondent disallowed certain deductions and determined that
petitioners are not entitled to certain exclusions they claimed
5This is the sum stated in the deficiency notice. We note
that the parties stipulated that Mr. and Mrs. Hargrove reported
amounts slightly different.
6This is the sum stated in the deficiency notice. We note
that the parties stipulated that Mr. and Mrs. Breeding reported
amounts slightly different.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011