Eric A. and Jane C. Lanigan - Page 7

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            on these Forms W-2 and 1099 attached to the returns as filed.  On                             
            each of the Forms W-2 attached to the returns, the box indicating                             
            petitioner was a statutory employee was checked.                                              
                  It is unclear whether the IRS representative, in completing                             
            the returns, used the records provided by petitioner or solely                                
            information she had available from IRS records.  The IRS                                      
            representative asked petitioner few questions, if any, and                                    
            indicated to him that the IRS had records of his income.                                      
            Petitioner knew that Form 1099 information is sent to the IRS,                                
            and he believed the IRS records present at the meeting contained                              
            information regarding his Forms 1099 income.  However, he took no                             
            steps to verify if that were the case.  There is no evidence that                             
            the IRS representative had available to her at that meeting any                               
            additional Forms 1099 or information about the items of                                       
            unreported income involved in this case.                                                      
                  Petitioner did not review the returns after the IRS                                     
            representative completed them and informed petitioner of the                                  
            amount owed.  He does not remember whether he was given copies of                             
            the returns at that time; he does not remember exactly what                                   
            records he took with him to the meeting.  What he does remember                               
            is being told that he owed over twenty thousand dollars including                             
            interest, that that amount was due within a 10-day to 2-week                                  
            period, and that if that amount was not paid promptly, he need                                
            not worry about his house because it would belong to the                                      
            Government.  Petitioner borrowed money to pay the taxes and                                   




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