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During the past 16 years you set aside funds for a
pension and invested in stocks and bonds while know-
ingly failing to file and pay your income taxes, de-
spite the fact that you had earned income from wages
and self-employment income. The fact that you filed
returns up until 1989 indicates that you were aware of
the filing and withholding requirements. You invested
your income during the past 16 years in lieu of filing
and paying your taxes, which indicates your failure to
file and pay your tax as willful and egregious.
Given your failure to propose any collection alterna-
tives and your non-compliance with the tax laws, the
Notice of Federal Tax Lien balances the need for effi-
cient collection with your concern that the collection
action be no more intrusive than necessary.
The notice of determination makes no determination with respect
to the respective notices of intent to levy issued with respect
to petitioner’s taxable years 2000 and 2001 and 2002.
Petitioner filed a petition with respect to the notice of
determination. In that petition, petitioner alleged:
5. The determination of the tax set forth in the said
notice of deficiencies are based upon the following
errors.
(a). The notices of deficiency did not take into ac-
count allowable cost bases for stock transactions.
(b). The notices of deficiency did not take into ac-
count certain allowable itemized deductions including
real estate taxes and other deductible expenses.
6. The facts upon which the Petitioner relies, as the
bases of the Petitioner’s case, are as follows:
(a). Petitioner’s income should be reduced by his costs
of securities sold and certain allowable itemized
deductions.
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Last modified: November 10, 2007