LAY, Chief Judge.
Robert G. Olson retained attorney Lee A. Magnuson to represent him during an Internal Revenue Service (IRS) investigation relating to Olson's tax liability for the years 1982, 1983, and 1984. In this capacity, Magnuson supervised the compilation of Olson's financial records and the preparation of income and expense summary sheets. From these materials he prepared the draft returns which were submitted to the IRS examiners. On April 2, 1987, the IRS...
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