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commenced against petitioner and Mazzilli during the years in
issue, Mazzilli filed for bankruptcy. As a result of Mazzilli’s
filing for bankruptcy, the mortgage on petitioner’s and
Mazzilli’s home was foreclosed. Petitioner was aware of the
foreclosure proceedings that had been commenced against Mazzilli
and her as well as of Mazzilli’s bankruptcy proceedings.
Petitioner and Mazzilli were divorced on October 28, 1999.
Petitioner held one or more jobs during 1997, 1998, and 1999. As
of April 29, 2004, petitioner had not filed Federal income tax
returns for either 1997 or 1999.
Petitioner’s and Mazzilli’s Joint Income Tax Returns for 1992
Through 1995
For 1992 through 1995, petitioner filed joint Forms 1040,
U.S. Individual Income Tax Return, with Mazzilli. Petitioner and
Mazzilli signed and filed their joint returns for 1993 and 1995
in February 1996 and their joint returns for 1992 and 1994 in
April 1996. These returns showed the following balances due:
$724 for 1992; $2,523 for 1993; $9,884 for 1994; and $695 for
1995. No portion of the amounts shown as due on these returns
was paid at the times that these returns were filed.
Mazzilli handled the preparation and filing of petitioner’s
and his joint returns for 1992 through 1995. Petitioner was not
aware that these returns showed balances due at the times that
she signed them because she neither reviewed these returns nor
asked Mazzilli whether these returns showed balances due.
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