- 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