Helen M. Korchak - Page 28

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          section 6015 with respect to an underpayment of tax for her                 
          taxable year 1982.  Petitioner is seeking relief under section              
          6015 with respect to an understatement of tax for that year.                
               In Part 3 of petitioner's Form 12510, petitioner provided              
          the responses indicated to the following questions with respect             
          to petitioner’s knowledge of any items that caused the under-               
          statement:                                                                  
               1a. At the time of signing, were you concerned about                   
                    any item(s) omitted from or reported on the                       
                    return(s)                                                         
                    9 Yes     : No                                                    
                  *       *       *       *       *       *       *                   
               1c. At that time, describe how much you knew about                     
                    each of the incorrect item(s)                                     
                    I did not know anything at all about the corrected                
                    item, Madison Recycling, LLC.  As previously                      
                    stated, I knew the return was prepared by our                     
                    accountant, a CPA, and by my husband of then 23                   
                    years.  I signed the return when asked because I                  
                    trusted my husband completely.  I believed that                   
                    since it had been reviewed and prepared by a CPA                  
                    and my husband, that everything was correct.                      
               2.   At the time of signing, if you were not concerned                 
                    about any item(s), when and how did your first                    
                    become aware of the incorrect item(s)                             
                    In 1988, the IRS sent a notice to us with a large                 
                    proposed 1982 tax liability because it intended to                
                    disallow a deduction related to Madison Recycling.                
                    I never knew about my husband’s investment in                     
                    Madison Recycling and the tax deduction until then                
                    when he informed me for the first time.                           
               Part 4 of Form 12510 listed, inter alia, various income                
          items and various expense items.  For example, the various income           





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