Janet H. Krasner, Petitioner, and Paul Krasner , Intervenor - Page 10

                                       - 10 -                                         
          advised petitioner that, in order to be able to pay their joint             
          tax liability for 1998, they needed to start setting money aside,           
          which Mr. Krasner told petitioner would require reducing the                
          amount that they were spending on household and other items.                
               On April 10, 1999, after Mr. Krasner reviewed and discussed            
          the 1998 joint return with petitioner as described above, peti-             
          tioner and Mr. Krasner signed that return.13  Sometime thereaf-             
          ter, the 1998 joint return was filed.14  When they filed the 1998           
          joint return, petitioner and Mr. Krasner did not pay the $38,324            
          of tax shown due in that return.                                            
               On August 5, 1999, Mr. Krasner sent petitioner an email (Mr.           
          Krasner’s August 5, 1999 email to petitioner).  Mr. Krasner’s               
          August 5, 1999 email stated in pertinent part:                              
                    I deposited $2,000 in your checking account yes-                  
               terday.  There is one more outstanding check that I                    
               wrote to pay the Visa charges from France for $2,300                   
               dollars.  That will leave you $1,786 for the month as                  
               of Wednesday.  I also checked the American Express                     
               charge and you have charged $1,000.  You will have to                  
               pay this bill out of your checking account when it                     
               comes on August 17.  If it’s not paid, American Express                
               will not allow any more charges.                                       

               12(...continued)                                                       
          tance of approximately $34,000, almost all of which he used to              
          pay off the outstanding joint liability for taxable year 1992.              
               13Schiffman Hughes Brown signed the 1998 joint return as the           
          paid preparer of that return.                                               
               14The record does not disclose the date on which petitioner            
          and Mr. Krasner filed the 1998 joint return.  Because the IRS did           
          not have a record of receiving the 1998 joint return, Mr. Krasner           
          sent a copy of that return to the IRS, which the IRS received on            
          May 2, 2000.                                                                




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011