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liabilities that would have been due on petitioner’s income had
petitioner filed separate Federal income tax returns.
During the years at issue, Alimam did not have any taxes
withheld from his income, and Alimam did not make any estimated
tax payments relating to his income.
In connection with the preparation of petitioner and of
Alimam’s joint Federal income tax return for each of the years
1981 through 1996, Alimam would gather the information relevant
to the preparation of the tax returns, including the Forms W-2
that petitioner provided to him, and take the information to his
accountant. The accountant would prepare the tax returns and
give them to Alimam. Alimam would sign the tax returns and then
generally give the tax returns to petitioner to sign, after which
Alimam would take the tax returns back from petitioner and mail
to respondent the signed tax returns.
On their 1993 and 1995 Federal income tax returns, however,
Alimam apparently signed petitioner’s signature.
Year after year (from 1981 through 1996) and without
petitioner’s knowledge (and also apparently without his
accountant’s knowledge), in his mailing to respondent of
petitioner and Alimam’s tax returns, Alimam would not include any
payment of the tax balances shown to be due on the tax returns as
filed, which balances related to unpaid taxes attributable to
Alimam’s income from his medical practice.
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