- 13 -
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
Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: May 25, 2011