Curtis B. Keene - Page 4

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               On or about February 10, 2001, a Form 1040X, Amended U.S.              
          Individual Income Tax Return, for the year 1991 was filed showing           
          that no income tax was due for that year and claiming a refund of           
          $2,837, which was the amount of Federal income tax withheld.  The           
          explanation petitioner gave for filing the 1991 amended return              
               Due to my ignorance, I mistakenly reported as “income”                 
               what were actually “sources” of income.  In addition,                  
               the amounts that I incorrectly listed as “income” were,                
               in fact, amounts that are exempt from taxation.                        
          There was a three-page attachment to the amended return in which            
          petitioner (not his spouse) made frivolous and groundless                   
          arguments why he did not owe the assessed tax.                              
               By letter dated April 25, 2001, the amended return and                 
          attachment were determined by the Examination Branch, Ogden                 
          Compliance Service Center, to be frivolous.  On November 1, 2001,           
          after receiving additional groundless statements from petitioner,           
          the Director of IRS Compliance Services disallowed petitioner’s             
          claim for refund.                                                           
               On January 21, 2002, respondent issued to petitioner a Final           
          Notice–-Notice Of Intent To Levy And Notice Of Your Right To A              
          Hearing with regard to petitioner’s unpaid Federal income tax for           
               On February 11, 2002, petitioner submitted to respondent a             
          Form 12153, Request for a Collection Due Process Hearing, which             
          attached a statement setting forth the following contentions:               

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