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