James D. Horn - Page 13

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               does not remember seeing any support for the                           
               adjustments in question.                                               
                    Records and working papers have never been made                   
               available to the taxpayer or the taxpayer is unaware                   
               that records and or working papers were provided to the                
               taxpayer from the agents to support the adjustments.                   
                    Sale of assets, settlements, and foreclosures has                 
               occurred at substantially less than fair market value                  
               without the taxpayer’s knowledge.                                      
                    Expenses paid by the taxpayer for the taxpayer’s                  
               corporation Horn Construction were never allowed and                   
               loans made to the corporation by Mr. Horn as an                        
               individual were never allowed as a deduction on the                    
               individual return.                                                     
               The case was originally set for trial on the Court’s October           
          2000 San Francisco trial session.  On July 27, 2000, the Court              
          granted respondent’s uncontested motion for continuance, which              
          was based on respondent’s then stated intention to file a motion            
          for partial summary judgment contesting petitioner’s right to               
          dispute the tax liabilities for 1990 through 1993.  The case was            
          thereafter reset for trial on the Court’s March 2001 San                    
          Francisco trial session.                                                    
               Respondent, in due course, filed a motion to dismiss for               
          lack of jurisdiction and to strike as to 1995.  The ground for              
          respondent’s motion was that respondent had not sent petitioner a           
          notice of lien or levy with respect to 1995.  The Court granted             
          respondent’s motion.  The record in this case contains no                   
          evidence regarding petitioner’s Federal income tax return,                  
          payments, examination or determinations by respondent, or any               

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