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Petitioner made some estimated tax payments for her taxable
year 1987. Mr. Golemb filed on petitioner's behalf requests for
extensions of time to file the returns for certain of the years
at issue.
At some time during the years at issue, petitioner discussed
with Mr. Golemb the fact that she had not received a tax bill
from the Service. During that discussion, petitioner and Mr.
Golemb speculated that petitioner had not received a tax bill
because respondent might have lost track of her records when her
surname changed after her divorce from Mr. Reynolds. At no point
did petitioner believe that she had a responsibility to contact
the Service because she had not received a tax bill for any of
the years at issue.
In March 1992, the Service sent petitioner a letter re-
questing that she telephone a revenue agent of the Service
(revenue agent) who was responsible for the examination of
petitioner in order to discuss her status as a nonfiler. Pe-
titioner never contacted the revenue agent. Consequently, in
April 1992, the revenue agent telephoned petitioner after having
obtained her telephone number through the Yellow Pages. During
that telephone conversation, the revenue agent told petitioner
that the Service had no records of her having filed returns since
1981 and requested that petitioner clarify her filing status. In
response, petitioner adamantly maintained that she had filed all
her returns. Subsequently, during the same telephone conversa-
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