Dori R. Merriam, Transferee - Page 4

                                        - 4 -                                         
               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.                                          

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  Next

Last modified: May 25, 2011