- 9 -
petitioner’s accountant, Philip Kenneth Ware, C.P.A., who had
prepared petitioner’s late-filed 1992, 1993, and 1994 income tax
returns and his 1990 and 1991 amended returns,3 petitioner’s
attorney, James Ganser, and petitioner’s daughter and bookkeeper,
Susan Azevedo, to discuss the audit results and petitioner’s
request that respondent waive the late-filing and accuracy-
related penalties. Agent Urrutia explained his adjustments,
answered questions, and informed those present he would concede
the penalties on the basis of the medical records petitioner had
provided about his psychiatric problems. At the conclusion of
the meeting, petitioner and his former spouse signed a Form 4549-
CG, accepting Agent Urrutia’s adjustments to their 1991 through
1993 returns, accepting disallowance of the carrybacks claimed on
their amended returns for 1990 and 1991, and showing deficiencies
in petitioner’s 1991, 1992, and 1993 income taxes of $146,459,
$108,404, and $15,762, respectively, plus substantial interest
accruals on the unpaid balances. The Form 4549-CG contained the
following waiver:
Consent to Assessment and Collection - I do not
wish to exercise my appeal rights with the Internal
Revenue Service or to contest in United States Tax
Court the findings in this report. Therefore, I give
my consent to the immediate assessment and collection
of any increase in tax and penalties, and accept any
decrease in tax and penalties shown above, plus
additional interest as provided by law. It is
3Mr. Ware thereafter prepared petitioner’s 1996 return.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011