William D. Little - Page 5




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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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