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3. Held, further, P is not entitled to relief
from collection for any of the years in issue because
he failed to establish his rights to any additional
deductions for any of those years.
James D. Horn, pro se.
John Y. Chinnapongse, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
BEGHE, Judge: Petitioner seeks review under section
6330(d)(1)1 of respondent’s determinations to proceed with levies
to collect unpaid assessments of individual income taxes, failure
to pay additions, and accrued interest for 1990 through 1994 and
1996. The taxable years and amounts of the assessments, as set
forth in respondent’s notices of determination, are as follows:
Taxable Amount of
Year Assessment
1990 $41,031
1991 354,250
1992 213,651
1993 13,550
1994 9,569
1996 33,875
Total 665,926
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years at issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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