- 3 - 1996, petitioner signed stipulated decisions in which she agreed that she had deficiencies in income tax of $1,113 for 1988 and $3,426 for 1989 and was liable for additions to tax of $272.30 for 1988 and $1,086.50 for 1989 for failure to file a return under section 6651(a) and failure to pay estimated tax under section 6654. Petitioner also agreed that respondent could assess and collect the deficiencies, additions to tax, and interest. Respondent assessed petitioner’s tax for 1988-89 on March 31, 1997. C. Petitioner’s Offer In Compromise Petitioner contacted Fast because petitioner received a notice (not otherwise described in the record) from respondent stating that she owed taxes for 1988-89. Fast told petitioner how to submit an offer in compromise, and that respondent would not consider her offer in compromise unless petitioner had filed all required tax returns. Fast checked respondent’s computer records and discovered that respondent had no record of petitioner’s having filed returns for 1991-95. Fast told petitioner that respondent would not collect taxes owed by petitioner for 1988-89 until March 20, 1998, to give petitioner time to submit an offer in compromise. At a time not stated in the record, a friend of petitioner’s delivered copies of what appeared to be two or three of petitioner’s returns to Fast. Those copies did not have originalPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011