- 10 -
raised no objections. Further, she admitted that her husband had
told her, prior to his death in 1987, that a tax problem had
arisen with the investment.7 He directed her to call Mr.
Pasternak if she had any questions regarding the investment or
the tax problems associated therewith. After her husband's
death, Mrs. Dornbrock called Mr. Pasternak to inform him of her
husband's death, but she did not discuss the Pop Phonomasters
program with him.
After the stipulated decision in this case became final, the
Internal Revenue Service (IRS) assessed the various deficiencies
and additions to tax in accordance with the decision. In March
1994, Mrs. Dornbrock received a letter from the IRS informing her
that she owed $17,267.81 for the tax year 1978. Believing that
this amount represented all of her tax liabilities, she paid this
amount in full. Shortly thereafter she received further
correspondence from the IRS informing her that she owed
$51,790.34 for 1979 and $15,043.26 for 1980. Upon receipt of the
correspondence referencing 1979 and 1980, Mrs. Dornbrock sought
the advice of a certified public accountant, who referred her to
an attorney. This series of events gave rise to the motion filed
on her behalf and that is presently before the Court.
7
At this time, Mr. Dornbrock had become aware that he was
terminally ill and was taking steps to prepare his wife to handle
financial matters after he had passed away. His efforts included
providing his wife with much financial information of which she
had previously, by her own admission, been intentionally unaware.
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