Janet H. Krasner, Petitioner, and Paul Krasner , Intervenor - Page 32

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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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