- 13 - The preliminary determination for 1998, 2001, and 2002 states that: (1) Petitioner’s reliance on Mr. Lepordo to take care of the tax matters did not establish a reasonable belief that the taxes would be paid at the time she signed the returns; (2) the fact that Mr. Lepordo did not have enough taxes withheld did not support relief; (3) she had knowledge of the unpaid balances when she signed the returns; (4) she did not establish that Mr. Lepordo was financially responsible; (5) she did not establish that Mr. Lepordo took responsibility for any portion of the unpaid taxes; and (6) she did not establish that Mr. Lepordo had the funds available or a specific payment plan at the time she signed the returns. The preliminary determination(s) for 1999 and 2000 is not in the record. The final determination merely states that the IRS was granting partial relief for 2000, but there is no explanation as to the IRS’s reasons for denying relief. Petitioner testified that she was not involved in the preparation of the returns, that she just gave her Forms W-2 to Mr. Lepordo, and his “tax guy did everything.” Petitioner also testified that she knew that partial payments were submitted for some years, while no payments were submitted in other years. Petitioner testified further that she told Mr. Lepordo that the taxes had to be paid, but “he told me not to worry about it, that, * * * he’ll take care of it.” On her Form 12510,Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 NextLast modified: March 27, 2008