- 13 - 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 whichPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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