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