Linda Sanders - Page 13

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          letters and the court documents received from Mr. Taylor.                   
          However, we do not find petitioner's contention to be persuasive.           
          Petitioner's interpretation of the two IRS letters centers on the           
          statement that she may not have to file a return.  Petitioner's             
          rendition of the letters is inaccurate.  The letters instructed             
          petitioner to complete enclosed worksheets to determine whether             
          she was required to file a return.  There is no evidence that she           
          attempted to determine whether she met the minimum filing                   
          thresholds.  Moreover, she received the first IRS letter in 1994,           
          after the 1992 return was due, and it is not reasonable cause for           
          her failure to file the 1992 return.  Additionally, the second              
          letter was not received until 1996 and is inapplicable in this              
          case.                                                                       
               Petitioner also argues that she reasonably relied on State             
          court documents from Texas in not filing her return.  In                    
          particular, petitioner asserts that she relied on Mr. Taylor's              
          professional opinion purportedly expressed in the State court               
          documents.  Although we believe that petitioner entered into                
          discussions with Mr. Taylor regarding her income tax liability,             
          the record does not support that she retained Mr. Taylor as her             
          attorney for income tax purposes.  The documents are simply                 
          insufficient to establish reasonable reliance on a professional.            
          See, e.g., Lust v. Commissioner, T.C. Memo. 1975-16.                        
          Additionally, the documents relate to a proceeding in which                 





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