Patricia Ann Blocker - Page 2

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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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