David M. Leggett - Page 10

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          told the revenue officer that he had only approximately $2,000 to           
          $3,000 of income for 1992.                                                  
               At the March 1996 meeting, petitioner told the revenue                 
          officer that he had asked the Service many times to show him what           
          provision in the Code required him to file returns, and he asked            
          the revenue officer to specify the sections in the Code and the             
          regulations that required him to file returns.  The revenue                 
          officer pointed out to petitioner that a notice issued by the               
          Service, which petitioner had brought with him to the March 1996            
          meeting, informed taxpayers that sections 6011 and 6012 required            
          taxpayers to file returns.  The revenue agent was not able to               
          cite for petitioner at the March 1996 meeting the specific                  
          sections of the regulations under those Code sections that                  
          elaborated on those filing requirements.                                    
               The revenue officer told petitioner at the March 1996                  
          meeting to send him a written request for abatement of the civil            
          penalties, which showed reasonable cause as to why the Service              
          should abate those penalties, and to submit his delinquent                  
          returns for 1992, 1993, and 1994.  The revenue officer informed             
          petitioner that he would request that petitioner's request for              
          abatement and delinquent returns be assigned to him, since he was           
          having the March 1996 meeting with petitioner and thus was                  
          familiar with those matters.                                                

               3  (...continued)                                                      
          return for 1995 was not yet due.                                            

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