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Memorandum, checked the box indicating acceptance of the settlement offer,
printed his and petitioner's names, signed his name, wrote in his up-dated
address, and mailed the Statement of Settlement back to the Hochman firm on
September 29, 1989.
Based on the Statement of Settlement received from Mr. Stillman and in
accordance with procedures established for this litigation project, respondent
was requested by the Hochman firm to send appropriate settlement documents
directly to Mr. Stillman, along with an enclosed return envelope to mail the
signed documents back to the Hochman firm. The documents (a Decision and a
Closing Agreement) were so transmitted and were signed and dated by Mr.
Stillman on November 27, 1989, forwarded to petitioner, signed and dated by
petitioner on December 18, 1989, mailed by petitioner, and received by the
Hochman firm on December 21, 1989. As noted earlier, it was not until April
13, 1990, that the Decision was submitted to and entered by the Court.
Petitioner understood that, as a result of signing the Decision, she had
an obligation to pay a deficiency in Federal income tax for 1981. Since
petitioner did not like owing a tax liability, she was anxious to make the
payment. Accordingly, petitioner had her accountant, Joseph Slattery, compute
her share of the final amount of tax, which she paid prior to receiving a bill
from the IRS. Petitioner looked to Mr. Slattery for computations, but she did
not believe that he represented her interests in the Tax Court case.
On June 10, 1986, a judgment dissolving the marriage between petitioner
and Mr. Stillman was entered, subject to the resolution of "reserved issues",
including disposition of substantial property interests. On February 4,
1988, petitioner signed her acceptance to a proposal made by her divorce
attorney to Mr. Stillman's divorce attorney, which included the following
language:
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