As a member of the staff (CLC) team assigned to work with Dave, you are assigned the individual task of developing a summary of the legal restrictions placed on the client, the areas of tax planning that you recommend for the taxpayer, and what sources of interpretation of tax laws, regulations, and rules (search audit trail to be included as citations and references) should be used by the staff (CLC) team.
Additional information provided by Dave during a previous meeting included the following:
a) Dave is under a full investigation by the Internal Revenue Service for failure to file tax returns for a former company, Tucson to Texas Travelers (3T), a sole proprietorship, which ran a series of truck stops between Tucson, AZ and Houston, TX until it was closed down due to net losses for the last 4 years of the 7 years it was in operation.
b) A document produced by Dave indicates that the former tax preparer had rolled over a net operating loss (NOL) into the last 4 years of tax returns prepared for the client.
c) You discover a handwritten note in the files provided that the NOL was used to offset taxable income in other business ventures for the taxpayer in each of the last four years of returns prepared for the taxpayer.
d) A single piece of paper was discovered in the prior tax preparers file that reveals that 3T had not prepared and submitted payroll reports including W-2s and 2099s for its last 3 years.