Patricia Williams, a.k.a. Patricia Richardson, a.k.a. Tish Martinson - Page 3

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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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