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for 1984 through 1989 at the times that these returns were due.
Sometime after learning of intervenor’s failure to file their
returns, petitioner confronted intervenor and convinced him to
seek the help of a public accountant with respect to their tax
matters. Petitioner and intervenor eventually filed their joint
income tax returns for 1984 through 1988 with the Internal
Revenue Service (IRS) on February 14, 1991. They did not,
however, file a joint income tax return for 1989, and they did
not pay their income tax liability for 1988 in full until
sometime after August 5, 1991. Despite intervenor’s previous
failure to file their joint income tax returns and to pay their
income tax liabilities in full, petitioner continued to rely on
intervenor to handle the preparation and filing of their joint
income tax returns during the years in issue.
Petitioner’s and Intervenor’s Joint Income Tax Returns for 1990
Through 1995
Petitioner and intervenor did not file their joint income
tax returns for 1990 through 1995 at the times that these returns
were due. Petitioner did not question intervenor about their
failure to file income tax returns for these years until it was
brought to her attention by intervenor. Petitioner and
intervenor eventually filed their joint income tax returns for
1990 through 1995 in the latter part of 1996. Petitioner was
neither forced nor coerced to sign these returns.
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