Clifford W. Miller - Page 4

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            from joint and several liability) with respect to the 1990 tax                             
            deficiency.  Around October 1993, respondent informed Ms. Bacon                            
            that respondent had decided to grant that relief to her.  None-                            
            theless, on March 7, 1994, respondent assessed the 1990 tax                                
            deficiency (assessed 1990 tax deficiency) against petitioner and                           
            Ms. Bacon.                                                                                 
                  For reasons not disclosed by the record, respondent inadver-                         
            tently and erroneously failed to adjust the joint account that                             
            respondent maintained for petitioner and Ms. Bacon (joint ac-                              
            count) in order to reflect the determination that respondent made                          
            around October 1993 to grant Ms. Bacon relief from joint and                               
            several liability.  Respondent ultimately became aware of respon-                          
            dent’s failure to adjust the joint account in order to reflect                             
            that determination.  On May 29, 1998, a so-called 2-Way Memo was                           
            prepared in which respondent’s personnel responsible for making                            
            changes to the joint account were instructed to transfer the                               
            assessed 1990 tax deficiency and interest thereon from the joint                           
            account to a nonmaster file (NMF) account to be established only                           
            in petitioner’s name (petitioner’s NMF account).  On June 18,                              
            1998, the assessed 1990 tax deficiency and interest thereon                                
            reflected in the joint account were transferred to petitioner’s                            
            NMF account.  At no time throughout the period during which                                
            respondent was considering and taking action with respect to Ms.                           
            Bacon’s request for relief from joint and several liability was                            

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