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After Mr. Golemb prepared petitioner's return for each of
the years at issue, he signed each such return in the space
designated for the signature of the return preparer but not in
the space designated for the signature of the taxpayer and mailed
the original of each such return to petitioner with a transmittal
letter. The transmittal letter that Mr. Golemb used to send
petitioner her return for each of the years at issue contained
precise and specific instructions to petitioner that she should,
inter alia, verify her name, address, and Social Security number
as they appeared in each such return, sign each such return, and
mail it and a check for any tax due to the Service (1) at the
address set forth in the transmittal letter or (2) in a pre-
addressed mailing envelope enclosed with that letter. Mr. Golemb
never informed petitioner that he would sign and file her return
for any of the years at issue.
Although petitioner received the return that Mr. Golemb
prepared for each of the years at issue within sufficient time to
file each such return on or before its due date, she did not file
any of those returns. Instead, she placed in her desk drawer
each of the transmittal packages from Mr. Golemb containing each
such return and Mr. Golemb's transmittal letter. As petitioner
received the return for each of the years at issue that Mr.
Golemb had prepared, she was reminded of her tax liability for
each such year.
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Last modified: May 25, 2011