Linda K. Haltom - Page 4

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          income of $439 in 1990 and $1,552 in 1992.                                  
               At the end of the audit, the IRS agent presented the Haltoms           
          with a completed Form 4549-CG that described in detail the                  
          calculations performed to arrive at the deficiency amounts.  By             
          signing the form, the Haltoms agreed that their total deficiency            
          from 1990 to 1993 was over $145,000.  The Commissioner also added           
          fraud penalties against Jerry that totaled over $100,000.                   
          Interest (computed only through the end of March 1997) brought              
          the total liability to over $370,000.                                       
               Throughout their marriage, and including the years for which           
          she is seeking relief from this very large liability, Linda                 
          shared a joint checking account with her husband into which they            
          deposited their paychecks.  Both spouses had signature authority            
          over the account, but Linda managed it, made most of the                    
          additional deposits to it, and wrote most of the checks on it               
          that went to pay household bills.                                           
               Jerry, however, kept five other accounts at five different             
          banks, including one in the Caribbean isle of Antigua.  He alone            
          had signature authority on these accounts.  While Linda knew that           
          Jerry had an account of his own for business, she was not aware             
          that there was more than one account or of the balances in any of           
          them, since Jerry took care to receive the statements at his                
          office.  He deposited all of his embezzlement income and whatever           
          prize money and bonuses he received into these five accounts, and           

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