Harvey I. Epstein and Arlene B. Epstein - Page 6

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          friend of Harvey and Arlene.  Arlene liked Kreindler and trusted            
          him.                                                                        
               Harvey did not explain petitioners' tax returns to Arlene              
          when he brought the returns for her to sign, which occurred                 
          sometimes early in the morning, when Arlene was not at her best             
          due to a chronic illness, and sometimes late at night when she              
          came in after reviewing a theater performance.  Arlene would                
          therefore call Kreindler when she had questions.  Kreindler would           
          assure Arlene that since he himself had signed the returns,                 
          Arlene could be assured that they were all right.                           
               In 1986, petitioners sold their Hewlett Bay Park house for             
          $725,000.  It was Arlene's understanding that petitioners had to            
          sell the house to "pay off taxes to the IRS".  Of the proceeds,             
          $305,000 were used to buy a house in Atlantic Beach, title to               
          which Arlene insisted be placed in her name alone because she               
          didn't know what Harvey's obligations were and she wanted to be             
          protected against claims of his creditors.  The increase in the             
          value of the Hewlett Bay Park house from approximately $118,000,            
          when purchased in 1973, to approximately $725,000, when sold in             
          1986, was unrelated to petitioners' putative tax savings from tax           
          shelter deductions in the relevant years.                                   
               Arlene received the proceeds from the sale of certain                  
          property which her father had owned, and on which she had paid              
          approximately $800 per year nominal real estate taxes for a                 





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