Cynthia K. Beatty - Page 6




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          and a State return for any taxable year after 1987 for which Mr.            
          Beatty had failed to file such returns.                                     
               In November 2001, Mr. Beatty’s accountant, Eric Vinson,                
          prepared a Federal return for petitioner and Mr. Beatty with                
          respect to each of their taxable years 1988 through 1997 and                
          2000, each of which petitioner and Mr. Beatty signed.  Those                
          returns, which respondent received on the dates indicated, showed           
          the following tax owed:                                                     

                                 Date Received                                        
                Taxable Year     by Respondent        Tax Owed                        
                    1988            11/7/01            $12,849                        
                    1989            11/7/01            13,644                         
                    1990            11/7/01            14,255                         
                    1991            11/7/01            14,823                         
                    1992            11/7/01            15,088                         
                    1993            11/7/01            15,533                         
                    1994            11/7/01            15,902                         
                    1995            11/7/01            20,726                         
                    1996            11/7/01            30,440                         
                    1997            11/26/01           41,174                         
                    2000            10/18/01           14,399                         
          (For convenience, we shall refer collectively to the Federal                
          returns that petitioner and Mr. Beatty filed jointly for the                
          taxable years 1988 through 1997 and 2000 as the joint returns for           
          the years at issue.)                                                        








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