James D. Horn - Page 1
















                                 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.                                                               








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