William C. and Elaine Gaskins - Page 15

                                                 - 15 -                                                    
            cards. He then met with Mrs. Gaskins about these items, told her                               
            of West Pine's delinquent employment taxes, and advised her of                                 
            her potential liability. Mr. Clark showed Mrs. Gaskins the West                                
            Pine checks and asked her about her signatures on the front of                                 
            those checks. Mrs. Gaskins told him that Mr. Quinn had signed                                  
            her name to the West Pine checks. In response to her concern                                   
            about the potential for another 100-percent-penalty assessment,                                
            Mr. Clark advised her to get an affidavit from Mr. Quinn                                       
            confirming that Mr. Quinn had signed her name and to have her                                  
            name removed from the bank signature cards. On a subsequent                                    
            visit in late 1981, Mrs. Gaskins told Mr. Clark that she could                                 
            not do that since she had signed the checks. In 1982, after the                                
            Gaskins' 1981 individual return had been filed, Mrs. Gaskins                                   
            contacted the family's tax return preparer for advice regarding                                
            West Pine's tax problems. The tax return preparer declined to                                  
            get involved or offer assistance. Mrs. Gaskins understood from                                 
            Mr. Gaskins that West Pine's tax liabilities and other bills                                   
            were discussed at meetings held in Philadelphia, meetings that                                 
            she did not attend.                                                                            
                   On September 14, 1982, IRS Revenue Officer Higgins                                      
            interviewed Mrs. Gaskins relative to the recommendation for a                                  
            100-percent-penalty assessment with respect to West Pine's                                     
            employment tax liability. During this interview, Mrs. Gaskins                                  
            stated that while she was not an officer of West Pine, she may                                 
            have been listed as comptroller. At trial, Mrs. Gaskins                                        




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