David C. Jonson and Estate of Barbara J. Jonson, Deceased - Page 10

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               Although Barbara was not present when David met the                    
          promoters of Vulcan and executed the subscription agreement and             
          the notes, she later reviewed the subscription agreement, and               
          David gave her a general explanation of the nature of the                   
          investment, expressing the view that it would provide substantial           
          tax savings to them.                                                        
               The subscription agreement contained the following                     
          representation by all those purchasing a limited partnership                
               I am aware that the tax effects which may be expected                  
               by the Partnership are not susceptible to certain                      
               prediction, and new developments in rulings of the                     
               Internal Revenue Service, court decisions, or                          
               legislative changes may have an adverse effect on one                  
               or more of the tax consequences sought by the                          
          Request for Section 6015 Relief                                             
               On June 13, 2000, David submitted to respondent a Form 8857,           
          Request for Innocent Spouse Relief (And Separation of Liability             
          and Equitable Relief) (the Form 8857), on behalf of the “Estate             
          of Barbara J. Jonson”.  David signed the Form 8857:  “David C.              
          Jonson (Personal Representative)”.  Among the attachments to the            
          Form 8857 is a document entitled “Statement of Estate of Barbara            
          J. Jonson * * * by David C. Jonson, Personal Representative”, in            
          which David states:  “Any financial benefits that resulted to the           
          Jonson family [from Vulcan] went into the general funds                     
          administered by David.  It eventually contributed to their normal           

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