- 9 - 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.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