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joint tax returns for 1974 through 1980 and for 1982. On the
joint tax returns for 1979, 1980, and 1982, Nancy signed as
"Nancy Silverman".
Sheldon did not bring the 1981 tax return home for Nancy to
sign, and although this tax return was signed with Nancy's name
(shown as "Nancy Jane Silverman"), Nancy did not sign this tax
return. Nancy did not realize that she had not signed the 1981
tax return, because (1) she had two small children to attend to,
(2) she did not contribute to the tax return preparation, and (3)
Sheldon's and Nancy's tax returns were usually filed with
extensions of time, and were not usually signed at the same time
every year. See supra table 1. The tax return preparer's
signature on the 1981 tax return is dated May 20, 1982; the
"Nancy Jane Silverman" signature on this tax return is dated May
21, 1982. At the time the 1981 tax return was filed, Nancy was
unaware of any tax problems regarding Sheldon, or his businesses,
or their joint tax returns. Nancy did not review the 1981 tax
return before it was filed; she did not see it until after
Sheldon died.
Pertinent information that petitioners reported on their
1981 through 1984 tax returns is shown in table 2.
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