- 22 - new data, her point, in this particular context, is not well taken. As a general matter, taxpayers are usually responsible for establishing their positions before the IRS. Second, on a more specific and practical level, petitioner, despite being represented by counsel, apparently never alerted the Appeals officer of any relevant change in circumstances. Furthermore, the types of items reported on the Form 12510 were not inherently of a nature to raise a suspicion of dramatic change over the course of the ensuing period. The only likely difference hinted at on the face of the Form 12510 would have been a reduction in income, as petitioner appended a comment that she might be unable to continue to sustain multiple jobs. However, third-party payers reported to the IRS even higher wages of $87,925 for the completed taxable year of 2003 (the most recent year for which records would have been available during at least the majority of the time petitioner’s case was before Mr. Pearce). This fact was noted by the Appeals officer in his recommendations. Third-party payers similarly reported still higher wages to petitioner of $90,974 for 2004. In this scenario, the Court, despite its admiration for petitioner’s efforts to help herself, is unconvinced that petitioner may abdicate all responsibility for raising some issue of pertinent change or, conversely, that thePage: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 NextLast modified: November 10, 2007