James M. Robinette v. Commissioner

123 T.C. No. 5

UNITED STATES TAX COURT JAMES M. ROBINETTE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 12052-01L. Filed July 20, 2004. On Oct. 31, 1995, P and R entered into an offer- in-compromise. The terms of the offer-in-compromise required P to, among other things, timely file his 1995 through 1999 tax returns. On the morning of Oct. 15, 1999, the day P’s 1998 return was due, P’s accountant (A) prepared P’s return. That afternoon, A drove to P’s office to obtain P’s signature on P’s return. A returned to his office. Thereafter, A affixed postage to the envelope…