William D. Little - Page 6




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          income of the estate in 1990.3  Petitioner timely forwarded these           
          forms to Mr. Lahr, who repeatedly advised petitioner that,                  
          because of the size of the estate, no taxes were due.                       
               In February 1992, respondent’s Kansas City Service Center              
          mailed a letter addressed to decedent proposing an income tax               
          liability for 1989.  In February 1993, the Kansas City Service              
          Center sent a notice of deficiency for 1989 that was addressed to           
          decedent.  A form letter proposing an income tax liability for              
          1990 was mailed addressed to decedent on March 1, 1993.  On June            
          7, 1993, a notice of deficiency for 1990 was mailed addressed to            

               3In petitioner's capacity as personal representative of the            
          estate, he received the following Forms W-2 and Forms 1099 for              
          taxable years 1989 and 1990:                                                
                      Documents/Forms                                                 
                     Received Jan. 1990   Payor        Amount                         
                     Form W-2     Federal Reserve Bank $54,137                        
                     Form W-2P    Boatman's Nat. Bank    3,040                        
                     Form 1099-G  Missouri Dept. of Revenue647                         
                     Form 1099-INTBoatman's Nat. Bank     237                         
                     Form 1099-INTUnited Missouri Bank     76                         
                     Form 1099-R  Thrift Plan for Employees5,000                        
                     Form 1099-R  Boatman's Bank         2,055                        
                     Form 1099-R  Boatman's Bank         6,611                        
                     Form 1099-R  Boatman's Bank         2,117                        
                     Form 1099-R  Boatman's Bank         2,309                        
                     Form 1099-R  Boatman's Bank         3,103                        
                      Documents/Forms                                                 
                     Received Jan. 1991   Payor        Amount                         
                     Form 1099-R  Thrift Plan for Employees96,485                        
                     Form 1099-R  Retirement Plan, Federal56,000                        
                     Form 1099-INTUnited Missouri Bank   2,072                        
                     Form 1099-INTUnited Missouri Bank   1,991                        
                     Form 1099-INTUnited Missouri Bank   1,990                        
                     Form 1099-INTUnited Missouri Bank   3,535                        
                     Form 1099-INTUnited Missouri Bank   3,347                        
                     Form 1099-INTUnited Missouri Bank   3,531                        




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