George C. Scrimshaw and Erna C. Scrimshaw - Page 6

                                         -6-                                          
          5, 1990, computations. The decision document was prepared in                
          accordance with the agreement reached by the parties.  On July 18,          
          1991, Dr. Scrimshaw mailed the signed decision document back to the         
          District Counsel's office.                                                  
               The stipulated decision was entered by the Court on July 26,           
          1991. The second page of the stipulated decision bears the putative         
          signatures for petitioner and Dr. Scrimshaw.  However, petitioner           
          did not sign this document, and it is unclear from the record who           
          did.5                                                                       
               On December 2, 1992, the IRS placed a tax lien on petitioner's         
          house.  In 1993, the IRS withheld a 1992 tax refund due petitioner          
          and applied it to the 1975 deficiency.  In 1994, the IRS placed a           
          freeze on petitioner's bank accounts, which was lifted only after           
          petitioner entered into an installment agreement with the IRS.  And         
          currently, the IRS has placed a levy on her wages.                          
               Petitioner filed an Offer in Compromise with the IRS, which            
          was rejected.  It was in the preparation of the Offer in Compromise         
          that petitioner, through her representative, realized that the              
          signature that purported to be hers on the stipulated decision              
          document was not hers in fact.                                              


               4(...continued)                                                        
                    provisions of I.R.C. sec. 6653(a).                                

               5    The parties agree that Richard Kestenbaum, petitioners'           
          then counsel, did not sign petitioner's name to the July 26,                
          1991, stipulated decision.                                                  




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