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additions to tax for 1987 and 1988, and the parties agreed that
petitioner was liable for a 1989 deficiency of $2,831 and an
addition to tax pursuant to section 6651(a)(1) for 1989. The
relevant facts are taken from the parties' submissions and the
existing record.
At the time the petition was filed, petitioner resided in
Rancho Mirage, California.
Background
In January 1989, the Internal Revenue Service (IRS) began an
investigation of petitioner's failure to file Federal income tax
returns for years 1982 through 1987. The investigation was later
expanded to include 1988 and 1989.
Investigation by Revenue Officer Lepkojus
Revenue Officer Ted Lepkojus investigated petitioner from
approximately December 18, 1990, to November 5, 1992. During the
course of his investigation, Revenue Officer Lepkojus had
difficulty locating petitioner due to her failure to file Federal
tax returns and her use of several different names. Letters and
postal tracers were sent to petitioner at her last known address,
but these efforts proved unsuccessful in locating her. Her former
attorney of record, Norman Axe, was also unsure of her whereabouts.
In March 1991, Revenue Officer Lepkojus was contacted by
Michael Kazanjian who indicated that he had paid petitioner
$124,000 in 1987 in exchange for her services as an interior
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