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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,
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Last modified: March 27, 2008