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Respondent assessed an additional tax of $13,629. By letter
dated, October 10, 1997, petitioner sought to establish that the
amount of disallowed wages was incorrect. During the so-called
audit reconsideration process, petitioner supplied virtually
identical notarized statements containing the names of four of
the alleged employees. By letter dated July 30, 2001, petitioner
was informed that the Social Security numbers were either missing
or invalid. Petitioner was requested to submit “either their
correct social security numbers or cancelled checks showing the
amount you paid to them.” Petitioner supplied further names and
Social Security numbers (but apparently no cancelled checks),
and, as a result, respondent abated $1,637 of the prior
assessment based on the examination.
Petitioner filed his 1996 Federal income tax return that
showed a balance due of $306. Petitioner admits that he owes the
amount shown on that return.
Respondent filed a lien pursuant to sections 6321 and 6323
and issued a notice of lien filing to petitioner pursuant to
section 6320. Petitioner timely requested a hearing contending
only that the amount of the 1995 deficiency was incorrect. On
September 5, 2003, respondent denied relief on the ground that
petitioner had waived his right to challenge the collection of
his 1995 tax liability because he had signed Form 4549-CG
consenting to the assessment and collection. Petitioner filed a
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Last modified: May 25, 2011