Vincent Allen - Page 3

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          deductions for charitable contributions, meals and entertainment,           
          and pager and computer expenses, as well as various other                   
          expenses.  Petitioner received complete copies of petitioner’s              
          returns for the years at issue after they had been filed, but he            
          did not file an amended tax return for either year.                         
               Two special agents of respondent’s Criminal Investigation              
          Division interviewed petitioner concerning Mr. Goosby’s                     
          preparation of his income tax returns.  Mr. Goosby was indicted,            
          tried, and convicted of 30 violations of section 7206(2)                    
          (willfully aiding and assisting in the preparation of false and             
          fraudulent income tax returns) in 2006, although petitioner’s               
          returns for the years at issue were not used as the basis for any           
          counts of the indictment.                                                   
               Respondent issued a deficiency notice to petitioner on March           
          22, 2005, in which respondent disallowed numerous Schedule A                
          deductions petitioner claimed on his returns for each of the                
          years at issue.  The deficiency notice did not assert the fraud             
          penalty under section 6663 against petitioner.  The regular 3-              
          year limitations periods for assessment of taxes with respect to            
          petitioner’s returns for the years at issue expired on April 15,            
          2003, and April 15, 2004, respectively.  Petitioner timely filed            
          a petition.                                                                 
               Petitioner has conceded all adjustments respondent made in             
          the deficiency notice other than one adjustment respondent                  
          concedes was made in error.  The parties agree that the false               
          deductions on petitioner’s income tax returns for the years at              





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