-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