Patricia S. Makalintal - Page 12

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          resources were available to him from his business interests in              
          the Philippines.  Ms. Yue and her supervisor accepted                       
          Mr. Makalintal’s explanation and finalized the return for                   
          Mr. Makalintal’s and petitioner’s signatures.                               
               When Mr. Makalintal gave petitioner the 1986 joint income              
          tax return for her signature, petitioner reviewed the return, and           
          petitioner also specifically asked Mr. Makalintal how                       
          Mr. Makalintal and she were able to afford such a high standard             
          of living in light of the income reported on the return.                    
          Mr. Makalintal informed petitioner that he had access to funds in           
          the Philippines that had been earned in years prior to 1986 and             
          that were not reportable as income for 1986.                                
               Because, among other reasons, Mr. Makalintal frequently                
          represented that his business interests in the Philippines were             
          successful and because Mr. Makalintal used an accounting firm to            
          prepare the income tax return, petitioner accepted                          
          Mr. Makalintal's explanation of the income reported on the 1986             
          return, and petitioner signed the return.                                   
               In connection with her review and signing of the 1987 and              
          1988 joint Federal income tax returns, petitioner again asked               
          Mr. Makalintal about the income reported thereon in light of the            
          money they were spending.  Mr. Makalintal again reassured                   
          petitioner that he had available nontaxable financial resources             
          from the Philippines.                                                       






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