Silvia S. Rodriguez - Page 3

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          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 original           






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