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master's degree in home economics from the same institution in
1963. After receiving her degrees, petitioner became a school
teacher, teaching at both the junior high and senior high school
levels. She continued teaching at the high school level until
1968 when she became a professor of home economics at the
University of Wisconsin, located in Stout, Wisconsin. Since
1968, petitioner has been a college professor. Petitioner's
expertise lies in the area of textile design and quality
analysis.
Petitioner's former husband, Mr. Peterson, was an attorney
who practiced law in Menomonie, Wisconsin, during the years at
issue. He was granted a power of attorney over the financial
affairs of Martha Burgess (Burgess) in 1985, following the death
of her husband. Mr. Peterson served in this capacity until
Burgess' death in 1990. After Burgess' death, her brother, Ralph
Grundman (Grundman), was appointed administrator of her estate
(the estate). Grundman retained Mr. Peterson to serve as the
estate's attorney. In February 1991, Grundman died and his
widow, Edna (Edna), replaced him as administratrix of the estate.
Mr. Peterson suffered a stroke in June 1991.
Sometime after February 1991, Edna, in her capacity as
administratrix of the estate, began receiving notices regarding
the estate's delinquent tax status. This concerned Edna, and she
initiated an inquiry into the estate's condition. An accounting
of the estate's assets provided by Mr. Peterson was incomplete,
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