Astrida Terauds - Page 15

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          were turned over to the IRS as a result of these levies.  At                
          trial, respondent produced IRS transcripts that reflected the               
          following amounts realized from these levies:                               
               For the 1986 tax year:                                                 
                    $   661.05     Sept. 28, 1992                                     
          918.29     Sept. 14, 1993                                                   
          3,084.23     Sept. 17, 1993                                                 
           54,532.26     July  17, 1991                                               
          $59,195.83     Total levies for 1986 tax year                               

               For the 1987 tax year:                                                 
          $3,823.00       Sept. 17, 1993                                              

               The Federal income tax returns of petitioner for 1986 and              
          1987, respectively, were received and filed by the IRS on                   
          April 16, 1992, and March 4, 1992.  Petitioner did not report               
          either the capital gain realized on the stock sales during 1986             
          nor any of the interest and dividends received on the stock, bank           
          accounts, and certificates of deposit that were jointly in her              
          and Sandra's names.  However, sometime after filing her 1986 and            
          1987 returns (and presumably feeling the sting of the sizeable              
          levies by respondent), petitioner came forward and made known to            
          the IRS that she and not Sandra owned the stock sold during 1986,           
          and that petitioner also owned all of the various bank accounts             
          and certificates of deposit that were titled jointly with Sandra.           
          In the resulting audit of petitioner's 1986 and 1987 tax years,             
          respondent determined the gain realized from the stock sales and            





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