Hugh Wilkinson and Evelyn Wilkinson - Page 5

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               Mrs. Wilkinson received a bachelor of science degree in                 
          nursing from City College and became a registered nurse in 1986.             
          Since that time, she has been employed sporadically.  In 1987,               
          she worked for 3 months as a registered nurse.  In 1991, she                 
          worked 2 days a week at Dr. Wilkinson's medical practice as a                
          registered nurse.  She knew that Dr. Wilkinson was working and               
          making money during this time and did not believe that he hid                
          money from her.  During the years in issue, she used Dr.                     
          Wilkinson's income to buy things that benefited her and the                  
          family, as well as to vacation in Florida.                                   
               In September 1988, Dr. Wilkinson had gall bladder surgery.              
          He did not resume working until January 1989.  Other than the                
          gall bladder surgery, Dr. Wilkinson did not have any other                   
          serious physical illnesses during the years in issue.                        
               Dr. Wilkinson did not undergo psychiatric evaluation during             
          the years in issue.  He saw Dr. Coleman, a psychiatrist,                     
          approximately 5 years after the last year in issue, for symptoms             
          of depression.  Dr. Coleman treated Dr. Wilkinson from June 1995             
          through February 1996, approximately three times a month.  Dr.               
          Coleman opined that Dr. Wilkinson suffered during the relevant               
          years from a personality disorder known as "double depression",              
          and that a symptom of this disorder is a neglect of                          
          responsibility such as failing to file tax returns.                          
          2.  Preparation of Federal Income Tax Returns                                

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