Carlye A. Christianson - Page 6




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               After Mr. Golemb prepared petitioner's return for each of              
          the years at issue, he signed each such return in the space                 
          designated for the signature of the return preparer but not in              
          the space designated for the signature of the taxpayer and mailed           
          the original of each such return to petitioner with a transmittal           
          letter.  The transmittal letter that Mr. Golemb used to send                
          petitioner her return for each of the years at issue contained              
          precise and specific instructions to petitioner that she should,            
          inter alia, verify her name, address, and Social Security number            
          as they appeared in each such return, sign each such return, and            
          mail it and a check for any tax due to the Service (1) at the               
          address set forth in the transmittal letter or (2) in a pre-                
          addressed mailing envelope enclosed with that letter.  Mr. Golemb           
          never informed petitioner that he would sign and file her return            
          for any of the years at issue.                                              
               Although petitioner received the return that Mr. Golemb                
          prepared for each of the years at issue within sufficient time to           
          file each such return on or before its due date, she did not file           
          any of those returns.  Instead, she placed in her desk drawer               
          each of the transmittal packages from Mr. Golemb containing each            
          such return and Mr. Golemb's transmittal letter.  As petitioner             
          received the return for each of the years at issue that Mr.                 
          Golemb had prepared, she was reminded of her tax liability for              
          each such year.                                                             






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