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filing the 1986 and 1987 joint Federal income tax returns for
petitioner and Mr. Martin, and the returns, ultimately, were not
timely filed. Mr. Forness did not discuss any position taken on
the Martins’ income tax returns with petitioner, and she was not
in a position to secure records from the various business
entities to prepare the 1986 and 1987 joint returns. Petitioner
did not receive any Forms W-2, Wage and Tax Statement, for the
period under consideration. Mr. Forness always presented the
joint Federal income tax returns to Mr. Martin, who in turn
presented them to petitioner for her execution.
After the Primera transaction, NCID and the insurance
regulatory authorities of two other States, focused on Life’s
financial situation and imposed restrictions. NCID, during 1987,
ordered that Life sell Primera. During 1988, Life sold Primera
to a development company for a $33 million promissory note linked
to the real property. Mr. Martin did not discuss these
difficulties with petitioner, and from 1984 through 1989, there
was no change in her lifestyle, and petitioner believed that she
was a wealthy person. Although petitioner was generally aware of
the Primera transaction, it was not until a few years after the
years in issue (sometime in 1990) that petitioner became aware of
the tax and insurance-related details and financial problems with
which her husband and family were confronted.
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