- 4 - October 9, 1995, were issued to petitioner relating to 1978 through 1984, and, as a result, petitioner was not entitled to challenge the underlying tax liability; and (4) for 1985 through 1992, 1994, and 1997, notices of deficiency were not issued to petitioner, and, as a result, petitioner was entitled to challenge the underlying tax liability. In respondent’s supplement to his trial memorandum, filed on January 28, 2002, respondent stated: (1) He failed, in his trial memorandum, to reference petitioner’s 1977 tax liability; (2) he misread the transcripts of accounts; the “quick assessments” noted on Forms 4340 indicated that petitioner had signed unspecified “agreements”; and petitioner was not the subject of jeopardy assessments relating to 1977 through 1984; (3) the tax liabilities assessed relating to 1977 through 1984 were either based on delinquent returns filed by petitioner or upon consent agreements signed by petitioner; and (4) as a result of the delinquent returns filed by petitioner or agreements signed by petitioner, respondent did not issue notices of deficiency to petitioner relating to 1977 through 1984 and cannot assert with certainty that petitioner is precluded from challenging the underlying tax liability; and (5) for 1985 through 1988, petitioner could not challenge the underlying tax liability because the assessments of the estimated tax and civil fraud penalties were based on agreements signed by petitioner.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011