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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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