Timothy R. and Cindy I. Fuller - Page 3

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               Petitioners’ tax returns for the years in issue were                   
          prepared by Wayne Greenfield (Greenfield), an enrolled agent in             
          Chico, California.  Petitioners provided Greenfield with                    
          schedules of gross receipts, cost of goods sold, and other                  
          expenses for 1998, 1999, and 2000 to aid him in the preparation             
          of their tax returns for those years.  Petitioner Cindy I. Fuller           
          (Mrs. Fuller) maintained the books and records for both of                  
          petitioners’ businesses.  She prepared the figures to be entered            
          on petitioners’ tax returns and provided them to Greenfield.                
          Other than contracts for the purchase of equipment, Mrs. Fuller             
          did not provide to Greenfield any underlying documents to                   
          substantiate how petitioners determined the figures that they               
          submitted to him to be entered on their tax returns.                        
               Petitioners filed their 1998 Federal income tax return on              
          October 19, 1999.  They filed their 1999 tax return on                      
          December 17, 2000.  They filed their 2000 tax return on June 7,             
          2002, after receiving from the IRS a letter requesting that it be           
          filed.                                                                      
               On their Schedules C, Profit or Loss From Business,                    
          petitioners understated their gross receipts by $73,624 for 1998,           
          $26,038 for 1999, and $9,931 for 2000.  They overstated their               
          costs of goods sold for materials and supplies by $27,768 for               
          1998, $49,019 for 1999, and $113,402 for 2000.  They overstated             
          their depreciation expenses by $17,558 for 1998, $26,037 for                






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