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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.
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Last modified: May 25, 2011