James D. Horn - Page 11

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          by sections 6330 and 6331.  One of the notices was for tax years            
          1991 through 1994; the other notice was for tax years 1990 and              
               Petitioner timely filed two requests, corresponding to the             
          two notices, for a section 6330 hearing.  In his requests for               
          hearing, in response to the portion of the form asking why the              
          taxpayer does not agree with the proposed levy, petitioner                  
          stated:  “I was absent for three years due to illness and am in             
          the process of restructuring a stockholders note that will have a           
          significant effect on my tax consequences I request a personal              
               Respondent’s Appeals officer held a hearing with petitioner            
          by telephone.  Petitioner did not provide any documentary or                
          other evidence to the Appeals officer that he was medically                 
          incapable of filing returns and waiving his rights to contest his           
          tax obligations prior to assessment.  Petitioner was unable to              
          make the Appeals officer understand how the current restructuring           
          of a stockholder note would have any effect on his prior years’             
          tax liabilities, nor did he present any evidence to support any             
          reduction in those liabilities.  Instead of responding to the               
          Appeals officer’s questions, petitioner talked about a perceived            
          conspiracy involving the vice president of Horn Construction, the           
          CIA, the FBI, the IRS, and the “Iranian Mafia”.  The Appeals                
          officer also spoke on the telephone with petitioner’s accountant,           

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Last modified: May 25, 2011