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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