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distributions from the estate were made on the advice of Mr.
Lahr. Petitioner and Mr. Lahr had no actual knowledge of the
estate’s income tax liabilities at the time these disbursements
and distributions were made.2
In January 1990, petitioner, in his capacity as personal
representative of the estate, received Forms W-2 and Forms 1099
for decedent which indicated that decedent had income in 1989.
In January 1991, petitioner also received Forms 1099 indicating
2Both petitioner and Mr. Lahr were credible when they
testified to their ignorance of the tax liabilities in question.
Indeed, respondent had no objection to petitioner’s requested
findings of fact, which stated:
Mr. Lahr was unaware of and ignorant of the debts due
the Government at the time distributions were made to
beneficiaries.
Petitioner was unaware of and ignorant of the debts due
the Government at the time distributions were made to
beneficiaries.
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