- 8 - tion with the revenue agent, petitioner stated that if her returns had not been filed, it was the fault of her return preparer, Mr. Golemb, who was responsible for filing petitioner's returns for her. Petitioner also told the revenue agent at another time that if the Service had no record of petitioner's having filed her returns, the Service must have lost her returns. On May 21, 1992, the revenue agent met with Mr. Golemb (May 21, 1992 meeting) who was authorized to represent petitioner with respect to the Service's examination of her. At that meeting, the revenue agent and Mr. Golemb agreed that petitioner had filed joint returns under the name Carlye Reynolds with Mr. Reynolds for 1983 and 1984. As for petitioner's returns for the years at issue, Mr. Golemb informed the revenue agent at the May 21, 1992 meeting that it was petitioner's position that originals of those returns had been filed with the Service. He told the revenue agent that he had retained copies of those returns that he could present to her. Later in the day on May 21, 1992, Mr. Golemb presented the revenue agent with copies of petitioner's returns for the years at issue. The copy of petitioner's 1985 return that Mr. Golemb presented to the revenue agent on May 21, 1992, was not signed or dated by petitioner. The original signature of petitioner appeared on each of the copies of petitioner's returns for 1986 through 1990 that Mr. Golemb gave the revenue agent on that day, but no date appeared next to her signature. The original of Mr.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011