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our previous letter. Please include your name, social
security number, signature declaration(“signed under
penalties of perjury”), signature date, and your reason
for disagreement. You have 10 days from the date of
this letter to appeal. [Reproduced literally.]
In response to respondent’s October 26, 2001 letter to
petitioner, petitioner sent respondent a letter dated November 1,
2001 (petitioner’s November 1, 2001 letter). That letter stated
in pertinent part:
The first issue is my signature on the return. I do
not recall signing this return. Furthermore, you say
that the return was not even received until May 2,
2000. I have absolutely no knowledge of a return being
sent in to the IRS at any time during the year 2000.
The only form I have knowledge of, is the Innocent
Spouse form I sent in during January of 2001.
During the years prior to the separation from my hus-
band, the accounting firm that handled all income tax
matters for my husband and myself was the firm of
Schiffman, Hughes and Brown in Blue Bell, PA. All
income tax forms were prepared by this firm. I was
never apprised that any return had not been filed in a
timely manner; not by my husband nor by the accounting
firm we had hired. I only found out that taxes were
still due when a notice arrived stating that my home
would be scheduled for foreclosure if the income taxes
due were not paid.
It was upon receiving this notice that I filed for
Innocent Spouse status with the government. The attor-
ney representing me at that time, Dorothy Phillips,
Esq. did not advise me to take this action, and refused
to help me in the process. * * *
* * * * * * *
It was on or about November of 1999, that I learned
that I had been on the payroll at Endodontics and
Endodontics Surgery PC, which is the name of the prac-
tice owned by my husband, Dr. Paul Krasner. I learned
that not only I, but also my four children had been on
the payroll as well. During the year in question, they
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