-6-
5, 1990, computations. The decision document was prepared in
accordance with the agreement reached by the parties. On July 18,
1991, Dr. Scrimshaw mailed the signed decision document back to the
District Counsel's office.
The stipulated decision was entered by the Court on July 26,
1991. The second page of the stipulated decision bears the putative
signatures for petitioner and Dr. Scrimshaw. However, petitioner
did not sign this document, and it is unclear from the record who
did.5
On December 2, 1992, the IRS placed a tax lien on petitioner's
house. In 1993, the IRS withheld a 1992 tax refund due petitioner
and applied it to the 1975 deficiency. In 1994, the IRS placed a
freeze on petitioner's bank accounts, which was lifted only after
petitioner entered into an installment agreement with the IRS. And
currently, the IRS has placed a levy on her wages.
Petitioner filed an Offer in Compromise with the IRS, which
was rejected. It was in the preparation of the Offer in Compromise
that petitioner, through her representative, realized that the
signature that purported to be hers on the stipulated decision
document was not hers in fact.
4(...continued)
provisions of I.R.C. sec. 6653(a).
5 The parties agree that Richard Kestenbaum, petitioners'
then counsel, did not sign petitioner's name to the July 26,
1991, stipulated decision.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011