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torneys. As part of her law practice, petitioner was mindful of
due dates for, inter alia, court appearances and filing doc-
uments.
Petitioner also served at various times from around the
early to mid-1980's until 1990 as a part-time judge of the Small
Claims Court, Municipal Court, and Superior Court in and around
San Diego, California. As part of her judicial duties, peti-
tioner imposed on litigants due dates for, inter alia, court
appearances and filing documents and kept track of those dates.
Petitioner has been aware since her youth of her annual
obligation to file a Federal income tax return (return). For
years prior to 1981, petitioner signed and filed her returns.
Petitioner married Doug Reynolds (Mr. Reynolds) in 1981, and
they divorced in 1985. While they were still married, petitioner
and Mr. Reynolds were the subject of an audit by the Internal
Revenue Service (Service) with respect to 1981 through 1983.
They retained Daryl Golemb (Mr. Golemb), a certified public
accountant, to represent them with respect to that audit.
Petitioner, Mr. Reynolds, and the Service resolved the audit of
1981 through 1983, as reflected in Form 870, Waiver of
Restrictions on Assessment and Collection of Deficiency in Tax
and Acceptance of Overassessment (1981-1983 Form 870). The 1981-
1983 Form 870 listed the names of the taxpayers to which that
form pertained as "Douglas R. and Carlye Reynolds". Attached to
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