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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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Last modified: May 25, 2011