Glenyce R. Peterson - Page 16

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          Peterson during taxable year 1991 were reported on the return and           
          that that amount totaled $45,000.  She claims that she                      
          specifically asked Mr. Peterson whether all embezzled funds were            
          reported on the return and that Mr. Peterson assured her that the           
          above-referenced $45,000 figure accounted for all such funds.               
          Further, petitioner asserts that she inquired at Mr. Peterson's             
          law office as to whether anyone there knew the actual amount that           
          Mr. Peterson had embezzled during 1991.  Office personnel, she              
          testified, told her that the estate had received special                    
          treatment and that, as a result of such treatment, and because no           
          paper trail had been created, the actual amount of Mr. Peterson's           
          embezzlement could not be determined.  Petitioner also claims to            
          have been told that the estate's file had been forwarded to an              
          attorney unaffiliated with Mr. Peterson's firm, and that, as a              
          result, she was unable to pursue the matter further.                        
               Respondent attempts to refute each of these allegations.               
          Specifically, she argues that, because Mr. Peterson was a known             
          embezzler and had suffered from a memory-impairing stroke the               
          prior year, it was unreasonable for petitioner to accept his word           
          that he had only embezzled $45,000 in 1991 and that all such                
          embezzled funds were reported on the couple's 1991 return.                  
          Instead, respondent claims, petitioner should have contacted the            
          attorney who had replaced Mr. Peterson as the estate's attorney             
          in order to determine the validity of Mr. Peterson's                        
          representation that all embezzled funds were accounted for in the           




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