Yvonne C. Lopez - Page 3

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          1999, she discovered he had made late bill payments that had                
          adversely affected her credit report.                                       
          Tax Returns                                                                 
               Petitioner and Mr. Cowdery filed joint Federal income tax              
          returns for 1992, 1993, 1994, and 1995.  Their returns reflected            
          unpaid income tax liabilities (tax liabilities) of $806, $1,729,            
          $1,705, and $1,394 for 1992, 1993, 1994, and 1995, respectively.            
          The tax liabilities resulted from underwithholding of wages                 
          attributable to both petitioner and Mr. Cowdery.                            
               Mr. Cowdery had their joint returns prepared by a tax return           
          preparer.  Petitioner gave Mr. Cowdery her Forms W-2, Wage and              
          Tax Statement, to take to the preparer.  When petitioner and Mr.            
          Cowdery received the completed returns and saw the amounts due,             
          Mr. Cowdery assured petitioner that he had talked to the return             
          preparer about payment plans and that he would make monthly                 
          payments on the liabilities.  Petitioner thought Mr. Cowdery was            
          making the payments on the tax liabilities because of Internal              
          Revenue Service (IRS) payments she believed to be in envelopes              
          she saw in their mailbox.  Petitioner did not know exactly what             
          was in the envelopes, however, and she never asked Mr. Cowdery              
          what was in them.  Petitioner also never saw any checks written             
          to the IRS by Mr. Cowdery.                                                  
               Sometime around October 1995, the IRS levied petitioner and            
          Mr. Cowdery’s bank account.  Petitioner first became aware that             






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