Eleanor Simon - Page 5

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               c.  Describe how, at the time you signed the return,                   
               you and your spouse planned to pay the tax due?                        
                    I was unaware of any taxes due because I did not                  
                    know that he had taken funds from his retirement.                 
               d.  Why did you file a joint return instead of                         
               married filing separate?                                               
                    We filed a joint return for thirty-three years                    
                    while living as husband and wife.                                 
          In petitioner’s Form 886-A, petitioner also alleged the following           
          with respect to the filing of the 1998 return:                              
               My former husband customarily had our return completed                 
               by H&R Block.  The additional [retirement] income was                  
               reported.  When the form was given to me for my signa-                 
               ture, my former husband insisted that I sign it quickly                
               in order to allow him sufficient time to get to the                    
               post office.                                                           
               In response to questions relating to the preparation of the            
          1998 return, petitioner alleged in petitioner’s Form 886-A that             
          her only involvement with the preparation of that return was to             
          give Mr. Simon Form W-2 for 1998 that she received from Guilford            
          College.  In this connection, petitioner further alleged in                 
          petitioner’s Form 886-A that Mr. Simon gathered the information             
          for the preparation of the 1998 return and delivered it to the              
          return preparer, that she never accompanied Mr. Simon when he               
          brought that information to the return preparer, and that Mr.               
          Simon retrieved the 1998 return from the return preparer after it           
          was completed.                                                              
               In response to questions relating to the existence of any              
          joint bank accounts, petitioner alleged in petitioner’s Form 886-           





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