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1993, disallowing deductions claimed on his 1992 and 1993
returns. The notice of deficiency was returned to respondent
because petitioner failed to claim it. The deficiencies were
assessed on August 4, 1995.
Petitioner claims that in May 1995 he received the “run
around” when he tried to resolve his tax liabilities. He claims
to have walked into the Oakland, California, branch of the
Internal Revenue Service, with his records but without a prior
appointment, demanding an immediate audit, but was turned away.
But in a letter dated December 28, 1998, petitioner admitted that
he did not actively pursue the matter until June 1997, when
respondent applied a later year refund to his assessed income tax
deficiencies:
Since my primary concern was finding a job in order to
pay for living expenses as well as paying back my debt
of $35,500 [for student loans], resolving this matter
with the IRS took a back seat because it was not going
to be as easy and straight forward as it should be [to
find a job] * * * As a taxpayer ignorant of the
bureaucratic gridlock that is pervasive throughout the
IRS, I became frustrated and gave up (until June 1997),
not having either the time or the energy to figure out
the ways of the IRS, I knew that I did not owe any
taxes and that sometime the IRS would contact me.
Petitioner filed a request for reconsideration of the
deficiencies on November 17, 1997.
Because petitioner had failed to attach documentation to his
request for reconsideration, respondent on January 29, 1998,
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