- 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
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