Harris Levin and Gayle Levin - Page 4

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          tax return.  Mr. Levin signed his name and Ms. Levin's name to              
          the Form 2848.  In August 1982, Anson and the IRS executed a                
          Form 872-A, extending indefinitely the period of limitations for            
          assessment of petitioners' taxes for 1980.                                  
               On September 17, 1985, the IRS sent to petitioners a                   
          statutory notice of deficiency, determining deficiencies of                 
          $41,609 for 1979 and $129,895 for 1980 in petitioners' Federal              
          income taxes.  On December 5, 1985, a petition was filed in this            
          case by Hochman and Gelfand as attorneys of record.  This case              
          was associated with numerous cases involving Schulman tax                   
          shelters.  On August 10, 1989, the decision was entered pursuant            
          to a stipulation bearing the original signature of Gelfand.  The            
          stipulation also bore a machine copy of signatures appearing to             
          be those of petitioners.  The decision determined that there was            
          no deficiency for 1979 and that there was a deficiency in                   
          petitioners' Federal income tax for 1980 in the amount of                   
          $129,895.  The decision became final 90 days thereafter.  Secs.             
          7481(a)(1), 7483.                                                           
               On December 4, 1991, petitioners delivered an Offer in                 
          Compromise to the IRS, seeking an agreement to reduce their                 
          liability for 1980 income taxes.  That offer was rejected on                
          February 16, 1992.  On May 13, 1992, petitioners filed a petition           
          in bankruptcy.  An order of discharge was dated September 11,               
          1992.  On July 16, 1993, a Notice of Levy on Wages, Salary, and             

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