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advised petitioner that, in order to be able to pay their joint
tax liability for 1998, they needed to start setting money aside,
which Mr. Krasner told petitioner would require reducing the
amount that they were spending on household and other items.
On April 10, 1999, after Mr. Krasner reviewed and discussed
the 1998 joint return with petitioner as described above, peti-
tioner and Mr. Krasner signed that return.13 Sometime thereaf-
ter, the 1998 joint return was filed.14 When they filed the 1998
joint return, petitioner and Mr. Krasner did not pay the $38,324
of tax shown due in that return.
On August 5, 1999, Mr. Krasner sent petitioner an email (Mr.
Krasner’s August 5, 1999 email to petitioner). Mr. Krasner’s
August 5, 1999 email stated in pertinent part:
I deposited $2,000 in your checking account yes-
terday. There is one more outstanding check that I
wrote to pay the Visa charges from France for $2,300
dollars. That will leave you $1,786 for the month as
of Wednesday. I also checked the American Express
charge and you have charged $1,000. You will have to
pay this bill out of your checking account when it
comes on August 17. If it’s not paid, American Express
will not allow any more charges.
12(...continued)
tance of approximately $34,000, almost all of which he used to
pay off the outstanding joint liability for taxable year 1992.
13Schiffman Hughes Brown signed the 1998 joint return as the
paid preparer of that return.
14The record does not disclose the date on which petitioner
and Mr. Krasner filed the 1998 joint return. Because the IRS did
not have a record of receiving the 1998 joint return, Mr. Krasner
sent a copy of that return to the IRS, which the IRS received on
May 2, 2000.
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