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an accountant to prepare the tax returns, including the Schedule
C for her medical practice. Petitioner did not review the
returns when she signed them.
Petitioner and Mr. Takamoto filed a joint Federal income tax
return for the taxable year 1979. On that return they claimed a
deduction in excess of $400,000 relating to an investment in
First Western Government Securities. Respondent disallowed the
deduction. See Freytag v. Commissioner, 89 T.C. 849 (1987),
affd. 904 F.2d 1011 (5th Cir. 1990), affd. 501 U.S. 868 (1991).
During 1984, respondent sent a notice of deficiency to petitioner
and Mr. Takamoto. Petitioner recalls receiving a certified
letter from the Internal Revenue Service, but never read, or was
otherwise informed of, its contents. Rather, she turned the
letter over to Mr. Takamoto. Mr. Takamoto hired Alan Farber (Mr.
Farber), an attorney, to represent petitioner and Mr. Takamoto
with regard to the dispute with the Internal Revenue Service. On
October 24, 1984, Mr. Farber filed a petition with this Court on
behalf of petitioner and Mr. Takamoto challenging respondent's
notice of deficiency. Petitioner and Mr. Takamoto separated in
1987. In 1989, Mr. Takamoto obtained an ex-parte Mexican
divorce.
On September 18, 1990, this Court entered a stipulated
decision that a deficiency in the amount of $68,756 in Federal
income tax and additions to tax under sections 6653(a) and
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