Janet H. Krasner, Petitioner, and Paul Krasner , Intervenor - Page 9

                                        - 9 -                                         
               On April 10, 1999, Mr. Krasner presented to petitioner                 
          completed joint Form 1040, U.S. Individual Income Tax Return, for           
          taxable year 1998 (1998 joint return), and reviewed at least the            
          first three pages of that completed return with her.  Those pages           
          showed, inter alia, wages of $242,248, “Business income” of                 
          $55,000 reflected in Schedule C, Profit or Loss From Business, a            
          loss of $4,483 from “Rental real estate, royalties, partnerships,           
          S corporations, trusts, etc.” reflected in Schedule E, Supplemen-           
          tal Income and Loss, Federal income tax (tax) of $66,361, total             
          tax payments of $28,037, and tax due of $38,324.11                          
               In reviewing the 1998 joint return with petitioner on April            
          10, 1999, Mr. Krasner informed her that they owed $38,324 of tax            
          for 1998 and that they needed to make arrangements with the                 
          Internal Revenue Service (IRS) to set up an installment plan to             
          pay that tax liability just as they had previously done with                
          respect to their joint tax liability for 1992.12  Mr. Krasner               

               11Around the end of 1998, Schiffman Hughes Brown, P.C.,                
          certified public accountants (Schiffman Hughes Brown), who                  
          represented Mr. Krasner and petitioner on, inter alia, their tax            
          matters informed Mr. Krasner that insufficient withholding had              
          been made for the first three quarters of 1998 with respect to              
          their projected tax liability for that year.                                
               12For taxable year 1992, petitioner and Mr. Krasner filed a            
          joint tax return (1992 joint return) that showed tax due, the               
          amount of which is not disclosed by the record and which they did           
          not pay when they filed that return.  During 1994, Mr. Krasner              
          and the IRS agreed to an installment plan about which petitioner            
          was aware and under which petitioner and he agreed to make                  
          monthly payments of their liability for taxable year 1992.  At a            
          time not disclosed by the record, Mr. Krasner received an inheri-           
                                                             (continued...)           




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