Paul Bryan Barrett - Page 4

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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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