Helen M. Korchak - Page 12

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          tax returns for petitioner and Mr. Korchak, including the joint             
          tax return for their taxable year 1982, and (2) the review,                 
          signing, and filing of such returns.  Mr. Sokol prepared a joint            
          tax return for Mr. Korchak and petitioner based on any Forms W-2,           
          IRS information returns, and other information provided to him by           
          Mr. Korchak.  Thereafter, Mr. Sokol gave that joint tax return to           
          Mr. Korchak who reviewed it.  After Mr. Korchak reviewed and                
          approved the joint tax return that the return preparer prepared,            
          Mr. Korchak presented that return to petitioner for her signa-              
          ture.  In presenting such joint tax return to petitioner, Mr.               
          Korchak had it open to the page on which petitioner and he were             
          to sign it.  Before petitioner signed the joint tax return that             
          Mr. Korchak presented to her, Mr. Korchak did not discuss its               
          contents with her, and petitioner did not review, or make any               
          inquiries about, such return.  The signature of the return                  
          preparer on the joint tax return that Mr. Korchak presented to              
          petitioner indicated to her that such return was prepared accu-             
          rately.                                                                     
               On April 28, 1983, the return preparer signed the joint tax            
          return for the taxable year 1982 of petitioner and Mr. Korchak              
          (1982 joint tax return).  The return preparer then sent that                
          return to Mr. Korchak.                                                      
               The 1982 joint tax return showed, inter alia, the following:           







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