David L. Wiksell and Margaret Ann Carpender - Page 5




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          David pleaded guilty to various counts of fraud involving the               
          sale of unregistered securities in connection with his                      
          participation in the fraudulent investment scheme.                          
               On their 1984 and 1985 returns, David and petitioner                   
          reported adjusted gross income of $10,525 and $4,298,                       
          respectively, of which approximately $9,801 in 1984 and $1,760 in           
          1985 represented petitioner's wages from part-time nursing.                 
          Petitioner signed the 1984 return on June 16, 1987, and the 1985            
          return on November 9, 1987.                                                 
               At the time she signed the 1984 and 1985 returns, petitioner           
          questioned David about why the returns contained no income                  
          reflecting the money that he had given her in those years.  She             
          stated that he gave her                                                     
               such a bizarre explanation that I don't think I could even             
               repeat it, I mean what he told me.  * * * It was something             
               along the fact that it had been investment--that he had                
               investments in * * * [Hitech] that had been lost and this              
               was return, or something along those lines.  * * * it just             
               didn't make sense to me.                                               
          Petitioner suspected that David was lying, but she would not                
          press him further on the matter.  David had gotten violent when             
          Margaret or others "probed" into his finances.                              
                                     Discussion                                       
               Reconsideration under Rule 161 serves the limited purpose of           
          correcting manifest errors of fact or law, also allowing for the            
          introduction of newly discovered evidence that could not have               
          been introduced before the filing of an opinion, even if the                
          moving party had exercised due diligence.  See Estate of                    


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