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notice for 1989 not received by petitioner was sent to
petitioner’s last known address.
FINDINGS OF FACT
Petitioner resided in San Marcos, Texas, at the time that
she filed her petition in this case. She was divorced from her
former husband in 1988. Petitioner married her present husband,
William P. Blocker (Blocker), in 1990.
Petitioner and Blocker did not file tax returns for 1990,
1991, or 1992 until December 17, 1998. As a result of their
failure to file timely income tax returns and various employment
tax-related matters, in or about 2000, petitioner and Blocker
attempted to resolve their outstanding tax liabilities by an
offer in compromise. In those efforts, petitioner and Blocker
were aided by an enrolled agent, Kathryn Womack (Womack). Womack
was informed that the offer in compromise would not be considered
unless and until petitioner and Blocker filed delinquent tax
returns. Womack prepared and submitted for petitioner a 1989 tax
return on which petitioner’s total tax was reported as $3,796.
The Internal Revenue Service (IRS) did not receive a 1989
Federal income tax return from petitioner prior to receipt of the
return prepared by Womack in 2000. On August 19, 1993, the IRS
sent to petitioner a letter stating that the IRS had no record of
receiving a return for 1989; that letter was sent to an address
on Bering Drive in Houston, Texas. On November 24, 1993, the IRS
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