Sandra L. Andary-Stern - Page 3




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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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