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Petitioner and James Merriam lived in the Tiburon residence.
Petitioner ran the family household. James Merriam controlled
their business and tax matters.
B. Ted Merriam
Ted Merriam graduated from law school in 1978. He received
a Master of Laws degree in taxation in 1982 and has practiced tax
law in Denver, Colorado, since then. Ted Merriam and his family
visited James Merriam and petitioner in California three or four
times a year from 1983 to 1999. Ted Merriam did legal work
related to James Merriam’s business activities, but he very
rarely spoke to petitioner about business or tax matters.
Petitioner signed joint individual tax returns that Ted
Merriam prepared for her and James Merriam. Petitioner knew that
Ted Merriam had prepared those returns. Petitioner signed a Form
2848, Power of Attorney, in which she and James Merriam
authorized Ted Merriam to represent them before respondent with
respect to their 1986 joint return. Ted Merriam received several
Forms 2848 purportedly bearing petitioner’s signature,2 including
one relating to petitioner’s transferee liability.
2 James Merriam frequently signed petitioner’s name to
documents. If the record shows that petitioner actually signed a
document, we state that she signed the document. Where the
record indicates that her signature appears on a document but
does not indicate that she signed it, we state that the document
“purportedly” bears her signature.
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Last modified: May 25, 2011