Padgett Coventry Price - Page 21

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          1991 tax returns.  Petitioner also admitted that the $10,000                
          check deposited in 1989 was income in 1989.                                 
               The court instructed the jurors that petitioner contended              
          she was not guilty of the crimes charged because she acted in               
          good faith reliance on a certified public accountant after full             
          disclosure of tax-related information.  The court further                   
          instructed the jurors that the good faith defense alleged by                
          petitioner was a complete defense to the charges in the                     
          indictment and that if the jury believed petitioner acted in good           
          faith they must acquit her.  The jury rendered a verdict finding            
          petitioner guilty on all three counts in the indictment.  On                
          January 28, 1999, judgment was entered in petitioner’s criminal             
          case.                                                                       
               Subsequent to her criminal conviction, petitioner was                  
          disbarred.                                                                  
          Petitioner’s Disability Insurance                                           
               On June 9, 1997, petitioner applied to reinstate a                     
          disability policy (disability policy) she held through the Paul             
          Revere Life Insurance Co. (PRLIC).  The application asked whether           
          since the date of application for the policy(s) to be reinstated,           
          but within 5 years, she had been treated by a physician or                  
          practitioner, been hospitalized or institutionalized, or been ill           
          or injured.  Petitioner responded that she had been treated by a            
          physician for a sore throat approximately 6 months before June 9,           






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