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decedent. These letters and notices were sent to petitioner’s
address, and petitioner received them. When petitioner received
these items, he gave them to Mr. Lahr, who continued to advise
petitioner that the estate was not liable for any Federal taxes.
Prior to closing the estate, in approximately May 1993, Mr.
Lahr engaged the services of Norman Dilg, a certified public
accountant, to review the administration of the estate. Upon
review of the estate records, Mr. Dilg discovered that certain
income tax returns had not been prepared and filed for decedent
and the estate. Mr. Dilg reconstructed the available financial
information and prepared and filed income tax returns in
September 1993 for decedent for the year 1989 and for the estate
for the years 1989, 1990, and 1991. Each of these returns
reflected an unpaid balance due. No payments accompanied the
returns.4
Mr. Lahr and petitioner became aware of the estate’s unpaid
income tax liabilities for 1989, 1990, and 1991 when Mr. Dilg
informed them, sometime after May 1993 and before the returns
were filed in September 1993. The only disbursements made after
4The returns filed for the estate showed the following
unpaid taxes:
1989 $4,654
1990 41,080
1991 52
The 1989 return for decedent showed an unpaid tax of $2,798.
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