Gary Friedmann - Page 6




                                        - 6 -                                         
                  In 1992, during the audit of petitioner's 1988 income               
             tax return, respondent's revenue agent requested copies of               
             petitioner's 1989 and 1990 returns.  In April 1992,                      
             petitioner gave photocopies of those returns to the agent.               
             At that time, the agent believed that petitioner had                     
             previously filed the returns with the Internal Revenue                   
             Service.  Petitioner gave the agent no indication                        
             otherwise.  Both returns had been signed before they were                
             photocopied, and neither return bore petitioner's original               
             signature.  In September or October 1992, the agent began                
             an examination of petitioner's 1989 and 1990 returns.                    
                  In due course, the revenue agent found that the                     
             Internal Revenue Service had no record of having received                
             either the 1989 or 1990 return.  The agent notified                      
             petitioner, by letter dated November 6, 1992, that the                   
             photocopied returns would be processed as delinquent                     
             returns once the agent received a copy of each return that               
             bore petitioner's original signature.  The agent's letter                
             states as follows:                                                       

                       As per our telephone conversation yesterday,                   
                  I will process the previously submitted copies                      
                  of your 1989 & 1990 1040 income tax returns as                      
                  delinquent returns since our records do not                         
                  indicate receipt of the aforementioned at the                       
                  service centers.  However, before I can process                     
                  the copies I need them to have original signa-                      
                  tures.  Please provide same above the copied                        
                  signature (also date) and return them to me so                      





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