Daniel C. Noonan - Page 8

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          no income in 1988.  Mrs. Noonan testified that if she had known             
          that petitioner had paid all tax liabilities related to taxable             
          year 1988, she would have signed the 1988 Federal return                    
          submitted by petitioner.                                                    
               On June 9, 1992, Ms. Burton mailed a letter to petitioner              
          advising him that she was unable to obtain Mrs. Noonan's                    
          signature and that he should file a 1988 Federal return as head             
          of household or married filing separate.  Ms. Burton did not file           
          the May return for the Noonans.                                             
               On June 12, 1992, Ms. Burton mailed Mrs. Noonan a Form 1040            
          for taxable year 1988.  Prior to mailing the Form 1040, Ms.                 
          Burton filled in the following information:  Mrs. Noonan's name             
          and address, her Social Security number, and zero gross income.             
          Mrs. Noonan completed the Form 1040 and returned it to the IRS.             
          Mrs. Noonan's 1988 Federal return was received by the IRS on July           
          1, 1992.  On the return, Mrs. Noonan reported no income, claimed            
          one exemption, and claimed married filing separate status.                  
               On November 19, 1992, petitioner received a letter from the            
          IRS indicating that a 1988 Federal return had not been filed by             
          him.  On January 3, 1993, petitioner filed another copy of the              
          1988 Federal return (the January return) reflecting his original            
          signature and a copy of the signature of Mrs. Noonan.  The tax              
          shown thereon was paid.  The original Form 1040 prepared in                 
          conjunction with the indemnification agreement and retained by              

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