- 3 - 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 aPage: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011