Michael Byard was employed as a computer analyst. His wife, Calvineta, was employed as a school nurse. Michael and Calvineta also operated a janitorial cleaning business that they reported on Schedule C of their form 1040.

Their tax returns for the years 2003 and 2004 were prepared by Joseph L. Wilson. Wilson claimed Michael Byard’s $24,000 deduction for a qualifying SUV on line 2 of IRS Form 2106: “parking fees, tolls, and transportation, including train, bus, etc., that did not ... Log in to view full article.