Joel Rappaport - Page 3

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          A.   Petitioner                                                             
               Petitioner lived in Florida when he filed the petition.                
          Petitioner graduated from New York University and received a                
          master’s degree from a second institution.  He is a certified               
          public accountant (C.P.A.), and practices in Florida and New                
          York.  He had specialized in taxation for about 40 years.  He               
          represented taxpayers before the Internal Revenue Service (IRS)             
          during 2001-04.                                                             
          B.   Petitioner’s Businesses                                                
               1.   Joel Rappaport & Co. and Rappaport, Steele & Co.                  
               Petitioner is the sole owner and president of Joel Rappaport           
          & Co., P.A. (JRC), a Florida corporation, and Rappaport, Steele &           
          Co., P.C. (RSC), a New York corporation.  JRC and RSC performed             
          tax, accounting, and return preparation services.                           
               Petitioner performed services for JRC in 2001-04.  He                  
          received $160,000 per year in wages from JRC.  In April of each             
          year from 1996 to 2004, petitioner signed annual reports for JRC            
          and filed them with the secretary of state of Florida.  JRC                 
          timely filed employment tax returns for 2002-04.  Petitioner                
          signed those returns.                                                       
               RSC provided tax and accounting services.  RSC was                     
          profitable in 2001.  In 2001-04, John Glasner and Bob Steele                
          (Steele) were RSC employees who provided accounting services and            
          prepared tax returns for RSC clients.  Steele represented clients           






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