- 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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