- 6 - According to petitioner, he filed a 1988 Federal return in March 1992 without payment of the tax liability shown thereon. Petitioner has no proof of mailing to show that he filed a 1988 Federal return at that time. The IRS has no record of receipt of that return from petitioner. In 1992, Carla Burton (Ms. Burton), a revenue officer at the Oxnard district office, began a taxpayer delinquency investigation to secure a 1988 Federal income tax return from petitioner. According to Ms. Burton, if there is no return on file, the usual procedure is to request an original return from the taxpayer. If the return subsequently submitted by the taxpayer is complete, the information appears accurate, and there are original signatures on the return, the usual procedure is to process the return by forwarding it to the teller function of the IRS. If the taxpayer advises her that a return has been filed, she would then request a copy of the return so that she could examine the return to determine if there is a mistake, such as a discrepancy in the Social Security number, on the return. The copy would not be processed because it would not contain original signatures. Ms. Burton typically documents in her notes whether she received an original return from the taxpayer. Ms. Burton attempted to secure the return from petitioner, rather than Mrs. Noonan, because his address was contained in her records. On May 20, 1992, Ms. Burton went to petitioner'sPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011