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Glenn collected and gathered the necessary documents to
enable WJ Hoyt Sons Laguna Tax Service, a Hoyt partnership-
related entity, to prepare his and petitioner’s joint Federal
income tax returns.
On or about July 25, 1991, on behalf of Glenn and
petitioner, WJ Hoyt Sons Laguna Tax Service prepared and
submitted to respondent a Form 1045, Application for Tentative
Refund, for the years 1987, 1988, and 1989, on which a claimed
$143,854 net operating loss relating to the Hoyt partnerships was
carried back from 1990. For 1990 through 1993, the same Hoyt
partnership-related tax preparer prepared Glenn and petitioner’s
joint Federal income tax returns.
During the years in issue, claimed Hoyt partnership-related
losses dramatically reduced Glenn and petitioner’s reported joint
adjusted gross income (AGI), resulting in Glenn and petitioner’s
receiving tax refunds of Federal income taxes paid for 5 of the 8
years in issue, and significantly reducing Glenn and petitioner’s
reported tax liabilities for the other tax years.
The schedule below reflects, for each of the years in issue,
Glenn and petitioner’s reported AGI before claiming the Hoyt
partnership-related items and their reported AGI after claiming
the Hoyt-related items:
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