William D. Little - Page 7




                                        - 7 -                                         

          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.                
                                                                                     




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next

Last modified: May 25, 2011