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recorded a notice of a $34,950 Federal tax lien with the Clark
County recorder in Las Vegas, Nevada.
In November 2000, petitioner applied for a position as pit
floor supervisor with ETT Gaming. On November 19, 2000, as part
of the application process, ETT Gaming purchased a consumer
credit report on petitioner, which petitioner reviewed. The
report showed the $34,950 Federal tax lien. Prior to reviewing
the credit report, petitioner was unaware of the Federal tax
lien.
On December 4, 2000, petitioner asked for help from the
Taxpayer Advocate Service in removing the Federal tax lien. The
Taxpayer Advocate Service arranged for petitioner to prepare
returns for each of the years for which respondent had assessed a
deficiency. Petitioner prepared Forms 1040, Individual Income
Tax Return, for 1987, 1988, and 1991 and joint returns for 1992,
1993, and 1994. On March 29, 2001, petitioner submitted the
returns to the Taxpayer Advocate Service, which forwarded them to
the appropriate Internal Revenue Service center for processing.
Processing included abating the previous assessments and
assessing the amounts shown on the returns prepared by
petitioner. It does not appear that petitioner submitted any
payment for the taxes shown on the returns she prepared.2
2The returns prepared by petitioner show much lower tax
(continued...)
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