Estate of Mark R. Woodward, Deceased, Lillian H. Woodward, Executrix, and Lillian H. Woodward - Page 5

          signed her name.4  Petitioner was not aware that her husband was            
          signing the Saxon documents on her behalf.  Mr. Woodward's                  
          actions were consistent, however, with petitioners' arrangement             
          for Mr. Woodward to manage the financial planning.  Although Mr.            
          Woodward did not discuss the Saxon investment with petitioner, he           
          did not conceal his business activities or the family's financial           
          affairs from her.                                                           
               On their joint income tax return for the taxable year 1983,            
          petitioners reported the putative income tax consequences of                
          their Saxon investment including claimed Schedule C deductions              
          totaling $14,168, and a claimed investment tax credit in the                
          amount of $20,500.  Concurrently with the filing of their return,           
          petitioners filed Form 1045, Application For Tentative Refund,              
          which generated refunds by carrying back unused investment tax              
          credits of $10,180, $9,620, and $700 to the taxable years 1980,             
          1981, and 1982, respectively.  Mr. Woodward prepared the joint              
          returns for 1980 and 1981.  Graham & Associates prepared the                
          joint returns for 1982 and 1983.                                            
               Petitioner signed each of the income tax returns that she              
          and Mr. Woodward filed with the Internal Revenue Service (IRS).             
          Petitioner also signed the Form 1045, Application For Tentative             
          Refund, filed with the IRS.  Petitioner trusted Mr. Woodward to             
          handle their financial matters, including tax return preparation.           


          4 Mr. Woodward signed petitioner's name on most of the Saxon                
          documents including the lease application, the business adviser's           
          questionnaire, the lease agreement, and the election to pass                
          investment tax credit from lessor to lessee.                                



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