115 T.C. No. 29
UNITED STATES TAX COURT
RAYMOND P. CORKREY AND MEGAN B. FLOM-CORKREY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18760-97. Filed October 24, 2000.
R received from the Social Security Administration
(SSA) inaccurate information showing that, during 1987,
P received certain compensation in the amount of
$35,100 for teaching a scuba diving course. In fact, P
received only $351 for such compensation. P did not
file a tax return for 1987 or 1988. On the basis of
the information from the SSA, R issued a notice of
deficiency to P, to which notice P did not respond. R
assessed the tax determined to be due and attached a
lien to P's bank account. During 1996, P was unable to
obtain a home loan because of the tax lien and
outstanding balances due to R. P hired an accountant
to prepare P's tax returns for 1987 and 1988. R
received P's 1987 and 1988 tax returns on Jan. 9, 1997.
P filed his 1987 return as married filing jointly, but
P's ex-wife did not sign the return and refused to sign
a declaration that P's 1987 return was true and
accurate. R would not process the return without P's
ex-wife's signature on the return or the declaration.
In addition to the problems with P's 1987 return, P's
1988 tax return contained significant errors. P
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