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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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