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understood that this report is subject to acceptance by
the District Director.
Petitioner understood the significance of the Form 4549-CG
he signed. He understood the specific tax issues raised by
respondent, disagreed with some of respondent’s conclusions, and
discussed with his attorney and accountant the relevant benefits
and burdens of accepting the adjustments. Ultimately, petitioner
accepted the recommendation of his advisers and signed the Form
4549-CG containing a waiver of his right to challenge the
adjustments prior to assessment and collection. Petitioner has
not paid the liabilities shown by the Forms 4549-CG he signed.
Respondent accepted petitioner’s 1994 return as filed.
Petitioner has not paid the tax liability shown on his 1994
return.
On or about November 24, 1997, petitioner filed his 1996
Federal income tax return. Petitioner reported total tax due of
$40,192. On May 5, 1998, respondent accepted petitioner’s 1996
return as filed. Petitioner did not pay in full the tax
liability shown on his 1996 return.
Respondent assessed the amounts determined on the Forms
4549-CG for 1990 through 1993, as well as the amounts shown on
petitioner’s returns for 1994 and 1996.
On February 9, 1999, respondent sent petitioner, by
certified mail, two notices of intent to levy and petitioner’s
right to request a hearing, both containing the language required
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Last modified: May 25, 2011