§695

695(c); Higbee v. Commissioner, 116 T.C. at 447. - 7 - Tax return preparers are defined in the Code as persons who prepare tax returns for compensation.9 For the year at issue, tax return preparers were required to provide their Social Security numbers or preparer tax identification numbers (PTIN) on any returns they prepared for compensation

695 (West 2002). The power at issue in this case states that it was to take effect at the surviving settlor’s death. As previously indicated, the estate’s contention that decedent’s exercise of her power of appointment never became effective rests on the relation-back doctrine under State law. Cal. Prob. Code section 282(a) (West 2002) provide

695.01(1) (West 1994). The failure to record the deed purportedly transferring the Vero Beach property from OIP to FIIC until almost 19 months after the transfer allegedly took place belies petitioners' contention based on Mr. Canty's testimony that OIP transferred the Vero Beach property to FIIC on February 28, 1992, in order to protect that