Estate of Barkat A. Khan, Deceased, Mohammed Aslam Khan, Executor - Page 9

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          with decedent or any other member of the Khan family.  After the            
          returns were completed, Lucchesi would pick up the returns and              
          take them to Aslam.  Aslam was not able to read the returns                 
          because of his poor eyesight.  Lucchesi did not review the                  
          returns in detail with decedent or Aslam.  Lucchesi merely told             
          Aslam where to sign the returns and whether there was any tax               
          owed or a refund due.  Aslam signed decedent's returns pursuant             
          to a power of attorney.5  Lucchesi then placed the signed returns           
          in envelopes and mailed them.  For taxable years before and                 
          including 1984, Aslam filed Forms 1040NR, U.S. Nonresident Alien            
          Income Tax Returns, for decedent.                                           
               In June of 1982, Aslam became a naturalized U.S. citizen.              
          After obtaining his U.S. citizenship, Aslam planned to have his             
          entire family come to the United States.                                    
               In March of 1984, Aslam went to Pakistan and met with                  
          decedent and the other Pakistani partners in an attempt to                  
          resolve differences among the partners.  In July of 1984, the               
          U.S. Department of Agriculture began requiring recipients of rice           
          program subsidies to have Social Security numbers.  Although                
          Aslam had a Social Security number, decedent, Mohammed Ali, and             
          Chrag had only temporary tax identification numbers.                        




               5  On Apr. 6, 1981, decedent executed a general power of               
          attorney, naming Aslam as his attorney-in-fact.                             




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