- 10 -
Petitioner also placed into evidence copies of the fronts of
two money orders in the amounts of $299.99 and $434, dated June
10, 1994, and September 3, 1997, respectively, and both made
payable to the IRS. The evidence does not indicate, however,
whether those money orders were ever negotiated. The IRS has no
record of having received either money order.
Without credible evidence showing that petitioner made
greater payments to the IRS than are reflected in the
transcripts, we cannot assume that petitioner previously paid the
tax liabilities respondent is now attempting to collect.
Accordingly, we conclude that respondent correctly determined
that collection efforts for taxable years 1991, 1992, 1993, 1996,
and 1997 should proceed.
Petitioner’s Request for a New Trial
On brief, petitioner requests that he be granted a new
trial and that a “tax attorney” be appointed to represent him.
Petitioner contends that with the assistance of a court-appointed
attorney he could obtain additional evidence to support his
contentions that he has already paid certain Federal income taxes
that respondent is seeking to collect.5
A rehearing is an extraordinary measure and will be granted
5 Petitioner mentioned at the end of trial that he might
have some records at home that would evidence his payments to the
Internal Revenue Service. We informed petitioner that we would
entertain a motion to reopen the record should he find any
records of his previous payments. Petitioner never made any such
motion.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011