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petitioner's 1988 return.
On March 12, 1997, Revenue Agent Anne Marie Meuse of the
Center's Substitute For Return Unit received petitioner's case
file, containing his 1987 and 1988 returns, along with
correspondence from his representative, Phillip J. Vecchio. Upon
receiving those materials, Ms. Meuse analyzed them for
discrepancies and problems. For the 1987 return, Ms. Meuse found
an issue concerning filing status and a discrepancy between the
Form W-2 from the school and the information received by the
Service. The Form W-2 attached to the return indicated $351 in
wages and the payor information received through the SSA
indicated $35,100 in wages, so Ms. Meuse assumed there was a
decimal point error. Ms. Meuse located the number for the school
on the Form W-2 to verify the information, because she wanted the
school to correct its Form W-2 information and submit the
correction to the Service, not just to the taxpayer.
In order to process petitioner's 1987 return, Ms. Meuse
required petitioner's ex-wife's signature. Petitioner had filed
the 1987 return as married filing jointly, and Ms. Meuse could
not process the return without both petitioner's and his ex-
wife's signatures. Because of the problems with petitioner's
account, Ms. Meuse contacted the accountant having a power of
attorney on file, Mr. Wojeski, but he no longer represented
petitioner and did not want to receive or supply any information
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