Anne C. Somervill - Page 5

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          Jackson.  In 1981, they acquired property at 1616 South Carolina            
          and, in 1982, property at 2501 North 25th Street.                           
               During the years in issue, Tim Radder, a certified public              
          accountant (C.P.A.), prepared petitioner and her husband's                  
          returns.  Petitioner's husband's secretary would compile the                
          information needed by the C.P.A. to complete the tax returns.               
          Petitioner would compile the information relating to the expenses           
          associated with her own real estate activities and any charitable           
          contributions that she made.  Petitioner would sign the return              
          when her husband's secretary called to tell her the completed               
          return was available.  Petitioner testified that no one ever                
          explained to her the different deductions or schedules on her tax           
          return, nor did she ask anyone to explain the return or the                 
          deductions on it.  Petitioner further testified, however, that no           
          one prevented her from examining the returns in issue; instead,             
          she simply chose not to examine them.                                       
               Petitioner testified at trial that she had no knowledge of             
          her husband's investments in either the Oxnard Properties or                
          Progressive Properties partnerships.  However, Sol Finkelman or a           
          member of his accounting firm, petitioner, and Robert Somervill             
          met for lunch or dinner, during which there was some discussion             
          of the Oxnard Properties and Progressive Properties.  Petitioner            
          testified that she did not understand what was being discussed as           
          to Oxnard Properties and Progressive Properties.  Nonetheless,              






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