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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
signature.
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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