Raymond P. Corkrey and Megan B. Flom-Corkrey - Page 10




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          process petitioner's returns until the time petitioner received             
          his refunds.  She also testified that, if the problem with the              
          Form W-2 information from the school showing a discrepancy in               
          wages and FICA wages had been brought to an examiner's attention,           
          the examiner would not have abated the tax without a tax return's           
          having been filed.  She stated that, even if the mistake had not            
          been petitioner's fault, the Service would have needed an                   
          original signed tax return, because he was still required to file           
          a tax return for his 1987 taxable year.                                     
               On May 30, 1997, the Service issued to petitioner refund               
          checks in the amounts of $451.39 and $226.97, respectively, for             
          his 1987 and 1988 taxable years.3  On June 2, 1997, the Service,            
          in response to correspondence dated March 24, 1997, abated for              
          reasonable cause, on the basis of a documented medical condition,           
          additions to tax for late filing and negligence that had been               
          assessed for petitioner's 1987 and 1988 taxable years.  Pamela              
          Auer, a revenue agent in respondent's technical unit that                   
          processed Congressional inquiries, including correspondence from            






          3    The record indicates that the refunds arose as a consequence           
          of (1) respondent's application of the refunds that petitioners             
          were due for the taxable years 1992, 1994, and 1995, against the            
          liability that respondent determined for the taxable year 1987,             
          and (2) petitioner's earlier payment of $2,022.55 against his tax           
          liability for 1988.                                                         





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