James D. Horn - Page 12

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          who agreed with respondent’s Appeals officer that petitioner                
          should submit an offer in compromise.  The accountant later                 
          informed the Appeals officer that petitioner was not interested             
          in pursuing an offer in compromise.  Respondent’s Appeals officer           
          concluded that respondent should proceed with collection because            
          petitioner failed to raise any legitimate defenses or                       
               On November 10, 1999, respondent issued petitioner Notices             
          of Determination Concerning Collection Actions under section 6320           
          and/or 6330, under which he determined to proceed with collection           
          by levy.                                                                    
               Petitioner timely filed a petition with this Court pursuant            
          to section 6330(d)(1), appealing respondent’s determinations to             
          proceed with collection by levy, alleging the “the deficiency (or           
          liabilities) as determined by the Commissioner are in income                
          taxes for the years 1990 through 1996”.  In the petition,                   
          petitioner claimed as follows:                                              
                    Taxpayer was mentally ill from 1993 to 1996 and                   
               unable to make rational decisions.  The service [sic]                  
               is aware of the illness.                                               
                    The taxpayer entered the year 1990 with a Net Fair                
               Market Value of Assets over Liabilities of $22,000,000.                
                    The taxpayer currently has no assets, only                        
                    Real estate values have increased since 1990.                     
                    The IRS has in examinations of several of the                     
               years, added tax and the taxpayer has never seen or                    

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