- 7 - residence to secure a 1988 Federal return. Petitioner was not at the residence, so Ms. Burton left a calling card instructing petitioner to telephone her the next day. On May 21, 1992, petitioner telephoned Ms. Burton and agreed to send a 1988 Federal return to her. According to Ms. Burton's investigation notes, on May 27, 1992, Ms. Burton received a 1988 Federal return from petitioner. That return (the May return) contained petitioner's original signature and a copy of Mrs. Noonan's signature. On May 28, 1992, petitioner advised Ms. Burton to obtain Mrs. Noonan's original signature on the May return, and on June 1, 1992, Ms. Burton mailed a letter and copy of the May return to Mrs. Noonan. In the letter, Ms. Burton advised Mrs. Noonan of the delinquency and missing 1988 Federal return. Ms. Burton also requested Mrs. Noonan's signature on the copy of the May return. On June 4, 1992, Mrs. Noonan telephoned Ms. Burton and told her that she did not want to sign the 1988 return submitted by petitioner because she did not know if the information on the return was correct and because she did not want to incur any liability related to that return. Mrs. Noonan also informed Ms. Burton that she received no income in 1988. Mrs. Noonan did inquire at that time as to the status of the joint refunds for 1986 and 1987. During their conversation, Ms. Burton allegedly advised Mrs. Noonan to file a separate return even though she hadPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011