My preparer colleagues are even now standing to their kit and bracing for the inundation of client requests for tender loving care and understanding as said clients drop off shoeboxes, totebags, and multi-part accordion envelopes (of the kind generically referred to by their older compères as RedWelds, a well-known brand).

These contain receipts, credit card statements, bank statements, brokerage statements, real estate closing statements, and pieces of paper “wretched, crinkled, scrawled over, blotched, frowsy.”

And from these, my colleagues and their trusty software craft the tax returns that furnish grist to today’s creaking mill in the Second Street, NW, Glasshouse.

DAWSON Opinions search function, restored, shows us that even the shoebox or RedWeld recordkeeping system, if the same as mother made, will stave off the Section 6662(a) chops. And though in the case of Maryann Patacsil, Docket No. 21903-19, filed 12/7/21*, much of IRS’ asserted unreported income and sketchy deductions o’ercrow Maryann’s little envelopes showing the expenses of her CA care home operations, Maryann escapes the chops.

CA care homes are residences for the serious disabled, or what are called group homes back East. Maryann got her learning from her Mom. Judge Holmes is at pains to point out Maryann’s engaging personality, care for her “consumers,” and her lack of accountancy or tax background. Mom was a “little envelopes” type of bookkeeper, the kind who dumps them on your desk and tells you “go to it.”

Most important, the years at issue were the early years of Maryann’s operations on her own.

“She had grown up in a business in which accounting system was bookkeeping via envelopes and receipts turned over to one’s CPA at the end of the year. Under these very special circumstances for these years early in her business career, I find she was reasonably relying on her mother and the accountant so I won’t sustain the penalty for her in any of these three years.” Transcript, at p. 19.

OK, preparers, “look how it comes again.”

*Maryann Patacsil Docket No. 21903-19 12 7 21