Angela Schwimmer - Page 10

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                On occasion, petitioner inquired of Martin as to the amount                  
          of his income and as to the family’s annual living expenses.                       
          Martin responded with vague and general answers and refused to                     
          provide any specific information to petitioner.                                    

          Martin and Petitioner's Joint Income Tax Returns                                   
          and Respondent's Audits                                                            
                For years prior to 1981, and for 1981, 1982, 1983, and 1984,                 
          Martin and petitioner filed joint Federal income tax returns.  It                  
          is not clear from the record who prepared the joint Federal                        
          income tax returns filed by Martin and petitioner for years prior                  
          to 1981.  For 1981 and 1982, Martin prepared the returns.  For                     
          1983 and 1984, an accounting firm prepared the returns with the                    
          assistance of Martin.                                                              
                After the tax returns for each year were prepared, Martin                    
          presented the returns to petitioner for her signature without                      
          giving petitioner any realistic opportunity to review the                          
          returns, presenting petitioner with the returns only after they                    
          had been prepared and insisting that she sign the returns                          
          immediately.  This was Martin's general practice with regard to                    
          all documents signed by petitioner.                                                
                The schedule below reflects Martin and petitioner's joint                    
          Federal income tax liabilities for 1970 through 1980 as reported                   
          on their returns:                                                                  

                              Year               Tax Liability                               





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