- 5 - number shown above. Please enclose a copy of this letter with any written correspondence. On April 15, 1999, Mr. Wilson held a telephone conference with Mr. Tilley in response to the request for a collection hearing. Both parties discussed the issues in the request. Mr. Wilson observed that there were four basic issues in petitioners’ protest and went over those issues with Mr. Tilley at that time. One issue discussed was a notice of intent to levy sent to Mrs. Tilley for years not applicable to her. Mr. Wilson discovered this had been corrected and that an appropriate notice of intent to levy had been sent. Another issue discussed during the telephone conference was the application of funds received by way of lien discharges and Mr. Wilson determined the funds had been properly applied. Mr. Tilley argued that he was entitled to certain deductions and credits. Mr. Wilson offered to send Mr. Tilley the transcripts of account. Mr. Wilson observed that the Tax Court had decided petitioners’ 1991 and 1992 years on the merits. As to 1994 and 1995, Mr. Wilson noted that Mr. Tilley, who had not filed returns for those years, was sent notices of deficiency but did not file a petition with this Court. The last issue Mr. Tilley and Mr. Wilson discussed during the telephone conference was that Mr. Tilley challenged the Federal income tax laws as being unconstitutional because they were capitation taxes. Mr. Wilson advised Mr. Tilley that it was not the function of Appeals to decide such questions but that these werePage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011