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that partnership's partnership return for 1986 from the IRS
Service Center.
On August 15, 1991, respondent issued the notice of
deficiency with respect to petitioner's tax liabilities for 1986
and 1987.
On November 12, 1991, petitioner filed her petition,
contesting the notice of deficiency issued to her for 1986 and
1987. On January 9, 1992, respondent filed an answer.
In a letter dated November 15, 1992, to her attorney,
petitioner stated as follows:
Mr. Sharer and I carried on a pretense of marriage in
order to protect his business and to promote an image
of stability. Even his secretary [Sandra Matsko]
didn't know the truth. Mr. Sharer was always telling
her various stories, as he did to other clients and
associates. Mr. Sharer told other people what he
thought they wanted to hear. One minute I was okay,
the next minute I was a witch and responsible for all
his problems. I think he wanted people to feel sorry
for him or to be "on his side" as his secretary was.
To this day I still (along with other clients) don't
understand that relationship. He was always going to
fire her but could never quite do it. If Mr. Sharer
and I were meeting clients, we always met at the
restaurant or office. No one ever came to my house
except for birthdays and holidays, at which people
would expect to see Derek's father and he would appear
for those occasions.
A copy of this letter was furnished to the IRS on November 30,
1992.
Shortly before trial, petitioner provided respondent with
copies of partnership returns for 1980 through 1985 to support
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