Walther Guerrier, Jr. - Page 8




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          of the years 1994 and 1996 should be reduced from the respective            
          tax liabilities for those years which respondent had computed and           
          assessed and to which the notice of intent to levy pertained.               
               At the February 12, 2001 Appeals Office hearing, the Appeals           
          Officer attempted to explain to petitioner respondent’s basis for           
          the tax assessment against him for each of the years 1994 and               
          1996.  The Appeals Officer explained to petitioner that respon-             
          dent calculated his tax liability for each of the years 1994 and            
          1996 by preparing a substitute for return for each of those years           
          on the basis of the information reflected in Form W-2, Wage and             
          Tax Statement (Form W-2), and Form 1099 that certain payors                 
          issued to petitioner for each of those years.  The Appeals                  
          Officer further explained to petitioner that, in preparing each             
          such substitute for return in order to arrive at petitioner’s tax           
          liability for each of the years 1994 and 1996, respondent deter-            
          mined petitioner’s tax bracket and the amount of tax due and                
          subtracted any credits to which he was entitled.                            
               Petitioner did not want to discuss at the February 12, 2001            
          Appeals Office hearing the amount of tax that he owed for each of           
          the years 1994 and 1996 or the proper way in which to prepare               
          Form 1040 for each of those years.  Nor did petitioner wish to              
          discuss collection alternatives at the February 12, 2001 Appeals            
          Office hearing.                                                             
               At the February 12, 2001 Appeals Office hearing, petitioner            






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