- 2 - FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. At the time he filed the petition, petitioner resided in Michigan. Around March 1994, the Internal Revenue Service (IRS) audited petitioner for 1990 and 1992. The audit resulted in proposed increases in petitioner’s income tax liabilities for those years. Petitioner knew that he could have appealed the proposed increases, but instead he agreed to them. On March 14, 2000, respondent mailed petitioner, via certified mail, a Final Notice, Notice of Intent to Levy and Notice of Your Right to a Hearing, with regard to his unpaid tax liabilities for 1990 through 1998. On or about April 10, 2000, respondent received from petitioner a timely Request for a Collection Due Process Hearing, Form 12153, (hearing request) with attachments. In the hearing request, petitioner stated: Petitioner admits that a certain obligation for taxes due the Internal Revenue Service exists, but denies any and all responsibility for said obligation for the reason that a prior assignment of a lien and its proceeds by Petitioner as grantor in favor of the United States and the IRS as a grantee was extinguished contrary to U.S. law through unlawful mortgage foreclosure proceeding concluded on December 15, 1994. Additionally, the mortgage foreclosed upon was a forgery. It appears that the proceeds of these crimes (proceeds which by prior tax liability are the legitimate property of the United States), arePage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011