T.C. Memo. 2002-207 UNITED STATES TAX COURT JAMES D. HORN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18502-99L. Filed August 16, 2002. P appeals under sec. 6330(d)(1), I.R.C., from R’s determination to proceed by levy to collect unpaid Federal assessments of income taxes, failure to pay additions, and accrued interest for tax years 1990-94 and 1996. 1. Held: P was mentally competent when he signed Forms 4549-CG, Income Tax Examination Changes, for 1990-93; by signing Forms 4549-CG, P waived his rights to dispute the tax liabilities for those years prior to assessment and thereby conclusively acknowledged that he had an opportunity to dispute those liabilities within the meaning of sec. 6330(c)(2)(B), I.R.C. 2. Held, further, P was mentally competent when he signed and filed his 1994 and 1996 income tax returns.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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