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having to face reality and are extremely angry with
him, something he is having a great deal of difficulty
tolerating. When we saw him on 7/19, he looked like he
had regressed significantly.
* * * * * * *
We are making every effort to try to treat him intensely
on an outpatient basis to prevent further regression,
and unless we do, most likely he will have to be re-
hospitalized.
In or around December 1994, respondent began examining
petitioner’s 1991 Federal income tax return and investigating his
Federal income tax liabilities for 1992 through 1994, for which
he had not yet filed returns. The examination/investigation was
performed by Revenue Agent Joe Urrutia.
In 1995, Horn Construction’s chapter 11 bankruptcy case was
converted to chapter 7. Petitioner filed a personal chapter 11
bankruptcy petition in 1996.
On March 18, 1996, petitioner and his former spouse filed
original joint Forms 1040 for 1992, 1993, and 1994, listing total
income taxes of $62,481, zero, and $22,097, respectively, and a
penalty of $1,106 for failing to pay estimated taxes for 1992.
On March 18, 1996, petitioner and his former spouse also filed
joint Forms 1040X, Amended U.S. Individual Income Tax Return, for
1990 and 1991, seeking refunds of $26,627 and $52,760,
respectively, attributable to carrybacks of a net operating loss
claimed from 1993. Petitioner and his former spouse did not pay
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