Sherry P. Aude - Page 6

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          Magnum, but Mr. Aude did not disclose the tax shelter nature of             
          the investment to petitioner.  She never saw the investment                 
          papers concerning Magnum, and she was unaware of Mr. Aude's                 
          capital contribution in Magnum.                                             
          1980, 1981, 1982 Joint Income Tax Returns                                   
               For the years at issue, Mr. Gruys prepared the Audes'                  
          Federal income tax returns.  He only occasionally talked with               
          petitioner, generally around the tax preparation time.  Instead,            
          he generally saw Mr. Aude.  Petitioner's main involvement in                
          completing the returns was to compile a list of household                   
          expenditures for Mr. Gruys.  She would accompany her husband to             
          deliver the list to Mr. Gruys.  After preparation, Mr. Aude would           
          present the returns, folded to the signature page, for                      
          petitioner's signature.  At these times, both Mr. Aude and Mr.              
          Gruys had already signed the return.  Prior to signing the                  
          returns, petitioner did not review them.                                    
               In regard to the Magnum investment, Mr. Gruys never reviewed           
          any papers regarding the investment.  In preparation of the tax             
          returns for the years at issue, Mr. Gruys relied on the Schedules           
          K-1 prepared by Magnum.  In advising the Audes, Mr. Gruys did               
          speak with Mr. Aude in passing regarding the validity of the                
          deductions for the investment, but he did not talk with                     
          petitioner about the deduction.                                             
               The joint returns for 1980, 1981, and 1982, as originally              
          filed, reflect income, Magnum deductions, adjusted gross income,            




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