Hector Prowse - Page 9

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          and petitioner was never a client of the firm.  To compound the             
          problem, petitioner submitted to respondent’s counsel, on October           
          14, 2004, yet another letter to substantiate the $1,300 legal               
          expense.  This letter, dated May 15, 2001, was purportedly                  
          prepared and signed by Paul Rubenfeld and purports to confirm               
          that Mr. Rubenfeld represented petitioner before the United                 
          States Bankruptcy Court for the Southern District of New York for           
          a fee of $1,300.  The Rubenfeld letter was falsified, and Mr.               
          Rubenfeld’s signature on the letter was forged.  Mr. Rubenfeld              
          did not represent petitioner before the Bankruptcy Court at any             
          time during 2001.                                                           
               On a date that does not appear in the record, the Internal             
          Revenue Service selected petitioner’s 2002 and 2003 tax returns             
          for examination.  On December 15, 2004, petitioner met with                 
          Revenue Agent Winslow, the agent who was assigned to conduct the            
          2002 and 2003 examination, and respondent’s counsel to discuss              
          petitioner’s claim that he was entitled to deductions for 2001              
          and to review the documentation needed for the examination of               
          petitioner’s 2002 and 2003 returns.  During that meeting,                   
          petitioner admitted that he personally had prepared some of the             
          third-party documentation that he had attached to his 2001                  
          return.                                                                     









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