Daniel C. Noonan - Page 7

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          residence to secure a 1988 Federal return.  Petitioner was not at           
          the residence, so Ms. Burton left a calling card instructing                
          petitioner to telephone her the next day.  On May 21, 1992,                 
          petitioner telephoned Ms. Burton and agreed to send a 1988                  
          Federal return to her.  According to Ms. Burton's investigation             
          notes, on May 27, 1992, Ms. Burton received a 1988 Federal return           
          from petitioner.  That return (the May return) contained                    
          petitioner's original signature and a copy of Mrs. Noonan's                 
               On May 28, 1992, petitioner advised Ms. Burton to obtain               
          Mrs. Noonan's original signature on the May return, and on June             
          1, 1992, Ms. Burton mailed a letter and copy of the May return to           
          Mrs. Noonan.  In the letter, Ms. Burton advised Mrs. Noonan of              
          the delinquency and missing 1988 Federal return.  Ms. Burton also           
          requested Mrs. Noonan's signature on the copy of the May return.            
               On June 4, 1992, Mrs. Noonan telephoned Ms. Burton and told            
          her that she did not want to sign the 1988 return submitted by              
          petitioner because she did not know if the information on the               
          return was correct and because she did not want to incur any                
          liability related to that return.  Mrs. Noonan also informed Ms.            
          Burton that she received no income in 1988.  Mrs. Noonan did                
          inquire at that time as to the status of the joint refunds for              
          1986 and 1987.  During their conversation, Ms. Burton allegedly             
          advised Mrs. Noonan to file a separate return even though she had           

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