Ruth E. Neal - Page 10

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               Specifically with regard to the years at issue herein, on                
          December 1, 1994, Alimam untimely mailed to respondent petitioner             
          and Alimam’s 1993 joint Federal income tax return on which return             
          petitioner and Alimam’s total joint Federal income tax liability              
          was reflected as $72,991 and on which return the only taxes shown             
          as paid were the $20,302 that petitioner had paid through income              
          tax withholding.                                                              
               On September 15, 1995, Alimam untimely mailed to respondent              
          petitioner and Alimam’s 1994 joint Federal income tax return on               
          which return petitioner and Alimam’s total joint Federal income               
          tax liability was reflected as $52,902 and on which return the                
          only taxes shown as paid were the $21,711 that petitioner had                 
          paid through income tax withholding.                                          
               On June 4, 1996, Alimam timely mailed to respondent                      
          petitioner and Alimam’s 1995 joint Federal income tax return on               
          which return petitioner and Alimam’s total joint Federal income               
          tax liability was reflected as $43,260 and on which return the                
          only taxes shown as paid were the $23,221 that petitioner had                 
          paid through income tax withholding.                                          
               Petitioner did not meet Alimam’s accountant until sometime               
          in 1996 soon after which petitioner and Alimam separated.                     
               Petitioner and Alimam’s joint Federal income tax returns for             
          1993, 1994, and 1995 were accurately prepared by Alimam’s                     








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