Lesley J. Smith, a.k.a. Lesley J. Scott - Page 12




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               On May 23, 2003, CCISO issued petitioner a preliminary                 
          determination denying her section 6015 relief for all years.  The           
          letter explained that CCISO had denied petitioner relief under              
          section 6015(b) and (c) for the 1993 and 1995 understatements of            
          tax because she had constructive and actual knowledge of the                
          computational errors, the errors were on the returns, and                   
          petitioner, having a duty to review the returns, failed to do so.           
          The letter explained that CCISO denied petitioner relief under              
          section 6015(f) for the understatements and/or underpayments of             
          tax for all years because petitioner did not establish that she             
          believed the tax would be paid at the time the returns were filed           
          and, having a duty to inquire as to how the taxes would be paid,            
          failed to do so.  Additionally, there were balances owed for                
          previous years when the returns were filed and a bankruptcy had             
          been filed.  The letter informed petitioner that she could                  
          request that an Appeals Office review the preliminary                       
          determination.                                                              
               Petitioner, Mr. Smith, and Mr. Scott and his new wife met              
          with petitioner’s clergyman, a bishop of the Church of Jesus                
          Christ of Latter-Day Saints (the LDS Church).  Mr. Scott told the           
          bishop that he had filed erroneous Federal income tax returns and           
          had kept that fact from petitioner and that he put the returns in           










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