United States v. Norma Moore, E. James Holmes, Fred Rodriguez, and Betty Florez
Court of Appeals for the Fifth Circuit
1Opinion of the Court
DeMOSS, Circuit Judge:
I
FACTS AND PROCEEDINGS
In 1987, E. James Holmes started a tax preparation organization for the primary purpose of assisting taxpayers in preparing amended income tax returns that would reflect substantial previously unclaimed deductions. Holmes’ fee for this service was 10% of the amount to be refunded. He required the taxpayers to pay him this amount in advance, in cash. Holmes also conducted classes on how to prepare such amended tax returns.
The government describes Holmes’ method of preparing these amended returns as a reverse process which starts with the total tax…
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