James D. Horn - Page 10

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               understood that this report is subject to acceptance by                
               the District Director.                                                 
               Petitioner understood the significance of the Form 4549-CG             
          he signed.  He understood the specific tax issues raised by                 
          respondent, disagreed with some of respondent’s conclusions, and            
          discussed with his attorney and accountant the relevant benefits            
          and burdens of accepting the adjustments.  Ultimately, petitioner           
          accepted the recommendation of his advisers and signed the Form             
          4549-CG containing a waiver of his right to challenge the                   
          adjustments prior to assessment and collection.  Petitioner has             
          not paid the liabilities shown by the Forms 4549-CG he signed.              
               Respondent accepted petitioner’s 1994 return as filed.                 
          Petitioner has not paid the tax liability shown on his 1994                 
               On or about November 24, 1997, petitioner filed his 1996               
          Federal income tax return.  Petitioner reported total tax due of            
          $40,192.  On May 5, 1998, respondent accepted petitioner’s 1996             
          return as filed.  Petitioner did not pay in full the tax                    
          liability shown on his 1996 return.                                         
               Respondent assessed the amounts determined on the Forms                
          4549-CG for 1990 through 1993, as well as the amounts shown on              
          petitioner’s returns for 1994 and 1996.                                     
               On February 9, 1999, respondent sent petitioner, by                    
          certified mail, two notices of intent to levy and petitioner’s              
          right to request a hearing, both containing the language required           

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