Ruthe G. Ohrman - Page 8

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          $6,443 in accuracy-related penalty, and $4,267 in interest) for             
          1999.  The letter of proposed changes was received by petitioner            
          at the Birdshill residence in early June 2001.  Within a few days           
          after receiving respondent’s letter of proposed changes,                    
          petitioner confronted Mr. Ohrman and learned of the early                   
          distributions from the Dean Witter account.                                 
          Legal Separation Proceedings and Transfer of Assets                         
               Within 1 week after receipt of respondent’s letter of                  
          proposed changes, petitioner met with Laura Rackner (Rackner), an           
          attorney in Portland who specializes in divorce and family law,             
          for advice.  During this meeting, petitioner told Rackner that              
          she received respondent’s letter of proposed changes for 1999.              
          In addition, petitioner told Rackner that Mr. Ohrman was a                  
          compulsive gambler and that she wanted to be protected from his             
          gambling-related debt.                                                      
               Rackner informed petitioner that there was a possibility               
          that she could obtain relief from joint and several liability for           
          the 1999 tax deficiency.  After hearing Rackner’s advice,                   
          petitioner told Rackner that she wanted a financial separation              
          from Mr. Ohrman.  Accordingly, petitioner provided assets and               
          liabilities information to Rackner, including the value of the              
          Birdshill residence and the value of the funds in Mr. Ohrman’s              
          Dean Witter account and in his 401(k) retirement account.  On               

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