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Janet Krasner objects and protests the denial of
innocent spouse relief and objects to being held con-
tinually liable for tax deficiencies solely arising out
of income generated by her husband, Paul, from whom she
is separated.
* * * * * * *
While Ms. Krasner does not have immediate recol-
lection of signing this return, she agrees that the
signature on the return bears sufficient resemblance to
hers that it is most probable the signature page of the
return was presented to her for execution. At the time
of the execution of the return, she also does not have
any recollection that it showed a tax deficiency which
was and remains unpaid.
During 1998 Janet Krasner was a stay at home mom
concerned only with the general welfare of her children
and was not knowledgeable nor did she have reason to
know the business details of her husband’s operation of
his practice. She was not acquainted with any of the
accounting details nor how her husband, Paul, kept his
books. Janet was not an employee of her husband,
Paul’s, endodontic practice. Assuming for purposes of
this supplemental Protest, Janet did sign the return,
she did not have any reason to believe that the returns
were any thing but correctly prepared and that the tax
would remain unpaid past its due date. Prior to the
tax return at issue, Janet had enjoyed a life of middle
class comfort and when such matters as tax return
preparation were presented to her, it was for the
ministerial act of receiving her signature with assur-
ances that all taxes had been paid. * * * Dr. Krasner
never indicated his inability to full pay his income
taxes and never urged Janet to “cut back” because of
impending economic problems.
* * * * * * *
While the Krasners marriage deteriorated, they
contineud to struggle with the hope of keeping their
marriage intact. Unfortunately, they have now sepa-
rated in part because of these finanical tax liabili-
ties and related problems. Ms. Krasner asserts that
she was the subject of spousal abuse, and that all of
the other factors for granting relief from the proposed
assessments are clearly present herein.
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