Diana T. Visco - Page 17




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          to satisfy her concerns.  Petitioner contacted the IRS and on the           
          basis of the advice of the IRS’s Taxpayer Service, timely filed a           
          Form 4868, “Application for Automatic Extension of Time To File             
          U.S. Individual Income Tax return” for 1992.  Petitioner again              
          attempted to obtain information from the district but was not               
          satisfied.  Petitioner contacted the IRS again and was advised to           
          contact the IRS’s Criminal Investigation Unit and to file a Form            
          4852, “Substitute for Form W-2, Wage and Tax Statement or Form              
          1099R, Distributions from Pensions, Annuities, Retirement or                
          Profit-Sharing Plans, IRA’s, Insurance Contracts, etc.”                     
               When petitioner contacted the Service’s Criminal                       
          Investigation Unit, she indicated that she wanted to complete her           
          1992 Federal tax return in a manner that would allow her to                 
          preserve her rights but that she did not know how to complete her           
          tax filing for 1992.  Petitioner requested an investigation into            
          the matter.                                                                 
               In August of 1993, petitioner filed a Form 2688,                       
          “Application for Additional Extension of Time To File U.S.                  
          Individual Income Tax Return” and notified the IRS that she still           
          had not received the information that she previously requested.             
          As a result, petitioner asserted that she did not know how to               
          file her return.                                                            
               The IRS sent Form 4598, “Form W-2, or 1099 Not Received or             
          Incorrect”, to the district indicating that petitioner’s records            





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