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12a. Was your (ex)spouse aware of any financial
problems you were having such as bankruptcy, high
credit card debt or difficulty paying monthly
living expenses? If yes, please explain.
I did not have any financial problems at the time.
13. If the tax years in question were audited, what
items, if any, changed? Were the changed items
yours or your (ex)spouse’s? (For example,
unreported income, disallowed deductions,
unclaimed credits)
The audit of my LTD. partnership [Madison
Recycling] disallowed my deduction and tax
credits. This was solely my investment.
* * * * * * *
15. If the items changed by the audit were yours, did
your (ex)spouse benefit from them? Explain.
No: The losses and tax credits resulted in a
refund of my withholdings. The refund was
invested in another business venture of mine which
failed in 1990. [Reproduced literally.]
On December 15, 2004, respondent received a memorandum from
petitioner’s attorney of record herein (petitioner’s December 15,
2004 memorandum). Petitioner’s December 15, 2004 memorandum set
forth (1) factual contentions that are substantially the same as
those set forth in petitioner’s attachment to petitioner’s Form
12507 and (2) legal arguments that are substantially the same as
those set forth in the posttrial briefs that petitioner filed
herein. Petitioner’s December 15, 2004 memorandum also stated in
pertinent part:
In 1982, unknown to Helen Korchak [petitioner],
her husband Ernest [Mr. Korchak] invested in various
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