- 4 -
According to the indemnification agreement, when the law firm
received money to pay the tax liability, it would then mail the
completed and executed 1988 Federal return to the Internal
Revenue Service (IRS).
When Mrs. Noonan signed the indemnification agreement, she
intended to file a joint 1988 Federal return provided petitioner
paid all the tax liabilities associated with taxable year 1988.
She would not have signed the indemnification agreement without
petitioner's agreement to pay the tax liabilities for 1988.
When petitioner and Mrs. Noonan signed the indemnification
agreement, Ron Pearson (Mr. Pearson) at the law firm was Mrs.
Noonan's tax counsel. After the indemnification agreement was
signed, petitioner provided Mr. Pearson with a completed 1988
Federal return. Mr. Pearson reviewed the completed 1988 Federal
return and supporting documentation with Mrs. Noonan. Petitioner
and Mrs. Noonan signed the completed 1988 Federal return, and it
was retained by the law firm. Sometime in 1990, Mr. Pearson left
the law firm and gave the completed and executed 1988 Federal
return to Mrs. Noonan's father, who was an attorney of counsel to
the law firm.
On October 26, 1990, the joint California return was filed
with the Franchise Tax Board in Sacramento, California. The
California return was signed by petitioner and Mrs. Noonan. A
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011