Connie A. Washington - Page 4

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          tax return preparer and signed the 1989 joint return.  Petitioner           
          had no other involvement in the preparation of the 1989 joint               
          return.  On the 1989 joint return, petitioner and Mr. Washington            
          reported (1) wages of $16,160 attributable to petitioner’s                  
          employment as a Federal purchasing agent, and (2) self-employment           
          income of $23,487 attributable to Mr. Washington’s carpentry                
          business.  After applying the $1,943 withholding from petitioner’s          
          wages, there remained a $4,779 balance due for 1989 (the unpaid             
          1989 tax liability).  The unpaid 1989 tax liability was not paid            
          when the 1989 joint return was filed.                                       
               No discussions took place between  petitioner  and  Mr.                
          Washington about the preparation or filing of the 1989 joint                
          return.  Nor did they discuss the payment of tax owed.  Petitioner          
          believed that because the unpaid balance of the tax shown on the            
          1989 joint return resulted from Mr. Washington’s failure to pay             
          estimated tax on his business earnings, he alone was responsible            
          for the payment of, and would pay, the tax owed.                            
               Petitioner and Mr. Washington were divorced in 1997.                   
          Petitioner received no assets from the dissolution of the marriage.         
          Petitioner was given custody of the two children.  Mr. Washington           
          did not pay spousal or child support to petitioner.  The divorce            
          decree was silent as to whether petitioner or Mr. Washington should         
          pay the unpaid 1989 tax liability.                                          








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