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Petitioner did not know that intervenor filed an offer-in-
compromise in 1993.
B. The Murrays’ Joint Federal Income Tax Returns
Intervenor was responsible for making estimated payments of
Federal income tax relating to income from his law practice. He
did not make these payments, even though he told petitioner that
he was doing so.
The Murrays filed joint Federal income tax returns for 1992
through 1996. Intervenor gave income tax returns to petitioner
to sign each year around April 14. Petitioner reviewed those
returns, on which the Murrays reported tax due (including
additions to tax for underpayment of estimated tax) of $11,131,
$14,933, $10,263, $2,114, and $6,252 for 1992, 1993, 1994, 1995,
and 1996, respectively. Petitioner knew that their taxes were
not being fully paid when the returns were filed, but intervenor
assured her that he would fully pay those taxes from his future
law practice earnings.
C. Events After the Years in Issue
The Murrays sold their home in mid-1997, and respondent
applied the proceeds ($18,818.96) to their tax liability for 1988
on June 16, 1997.
The Murrays filed for bankruptcy under chapter 13 in
September 1997. The bankruptcy case was dismissed on August 5,
1998. No taxes were discharged in that proceeding.
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