Thomas R. Hochschild, Sr. - Page 10




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          requires that the taxpayer “have an opportunity to dispute such             
          tax liability.”                                                             
               2.  Petitioner’s Arguments Concerning the Underlying Tax               
          Liability.                                                                  
               As outlined previously, petitioner, contends that he was not           
          able to find out any factual information, even though he had                
          filed a request under the FOIA, and that he questions the                   
          validity or substance of respondent’s determination.  Petitioner            
          also contends that respondent has conspired with the NLRB as part           
          of a Governmentwide conspiracy against him and his family.                  
               Regarding petitioner’s first contention, respondent’s                  
          Appeals officer, in a letter to petitioner, provided him with an            
          explanation of the source of the income adjustments determined in           
          the statutory notice.  She explained that the income items were             
          based on Forms W-2 and 1099 from petitioner’s own companies.                
          Petitioner wishes to ignore that information and instead argues             
          that respondent has failed to provide the information he asked              
          for in his FOIA request.  Again, respondent’s Appeals officer               
          explained to petitioner, by letter, that his request had not been           
          honored because he refused or failed to agree to pay the required           
          fee.                                                                        
               Petitioner’s FOIA request was asking for the same                      
          information as was provided by respondent’s Appeals officer;                
          i.e., the basis for the income tax liability.  The documents upon           






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