Raymond P. Corkrey and Megan B. Flom-Corkrey - Page 1

                                   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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