Michael Norton - Page 3

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          would not claim an interest of any kind in the seized funds.  The           
          plea agreement concludes with statements acknowledging that                 
          petitioner had adequate time to discuss the case with his                   
          attorneys, his attorneys provided him all the legal advice he               
          requested, he made the plea voluntarily, no one coerced or                  
          threatened him to enter into the plea agreement, and his                    
          attorneys explained all the rights he had as a criminal defendant           
          and all the terms of the plea agreement.                                    
               Petitioner was represented during his criminal trial by two            
          experienced criminal defense attorneys, Penelope Cooper and Ted             
          Cassman.  Petitioner’s attorneys signed the plea agreement and              
          stated that petitioner understood all the terms of the plea                 
          agreement, and that petitioner’s decision to plead guilty was               
          knowing and voluntary.                                                      
               On November 14, 2000, petitioner signed a Form 4549, Income            
          Tax Examination Changes, for 1995.  Petitioner agreed to a                  
          $440,042 deficiency in tax and a $330,031.50 fraud penalty                  
          pursuant to section 6663 for 1995.  The Form 4549 listed                    
          $367,289.70 in interest due as of November 23, 2000.  Above the             
          signature block Form 4549 states:                                           
               Consent to Assessment and Collection--I do not wish to                 
               exercise my appeal rights with the Internal Revenue                    
               Service or to contest in the United States Tax Court                   
               the findings in this report.  Therefore, I give my                     
               consent to the immediate assessment and collection of                  
               any increase in tax and penalties, and accept any                      
               decrease in tax and penalties shown above, plus                        
               additional interest as provided by law. * * *                          

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