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(11) whether the statute of limitations bars the assessment
and collection of the deficiencies in tax, additions to tax, and
penalties that respondent has determined against petitioner for
1988, 1989, and 1990.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, the second stipulation of facts, and
the attached exhibits2 are incorporated herein by this reference.
Petitioner resided in Williamstown, New Jersey, when he
filed his petition in this case.
During the years in issue, petitioner was married to Bonnie
E. McNamara (formerly Bonnie E. Moran). Petitioner and Bonnie E.
McNamara (Ms. McNamara) maintained a personal joint checking
account at Continental Bank during the years in issue.
Petitioner and Ms. McNamara are now divorced.
Ernest Agresto, a certified public accountant, prepared
petitioner and Ms. McNamara’s joint income tax returns for the
years in issue. Mr. Agresto prepared these returns using
information supplied by Ms. McNamara. With petitioner’s
permission, Ms. McNamara signed petitioner’s name on their joint
2 Respondent has objected on the grounds of relevancy and/or
hearsay to the admission of the following exhibits: 176-P
through 179-P, 183-P through 215-P, 222-P, 223-P, 227-P through
230-P, 232-P through 235-P, 237-P, 238-P, 243-P, and 244-P. At
trial, we reserved ruling on these exhibits. We have considered
each of the exhibits in question and find that they do not
justify any alteration in our findings of fact.
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