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certain record companies over royalties due him in connection
with songs he had written. He asked the assistance of the
Internal Revenue Service (IRS) to subpoena information from the
record companies so that he could make proper returns.2 Other
than asking for such assistance, he did not propose any
alternatives to collection.
On November 15, 2001, an Appeals officer held the hearing
petitioner had requested. At the hearing, petitioner stated that
he had filed the returns so as not to get into trouble and that
he had not paid the taxes shown because he did not believe the
amounts to be correct. He would not say whether he believed his
correct income to be higher or lower than the amounts reported.
Although the Appeals officer concluded on the basis of section
6330(c)(2)(B) that petitioner’s underlying tax liabilities were
not properly at issue, he advised petitioner that he could file
amended returns adjusting the tax shown on the returns.
Petitioner declined to do so.3
As required by section 6330(c)(1), the Appeals officer
verified that the requirements of applicable laws and
2 Both at and before the hearing petitioner requested,
petitioner was advised that the IRS had no authority to intervene
in his dispute with the record companies by subpoenaing
information from them for him.
3 Subsequently, petitioner was provided with blank Forms
1040X, Amended U.S. Individual Income Tax Return, along with the
accompanying instructions, for his use should he change his mind
(apparently, he has not done so).
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Last modified: May 25, 2011