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On May 2 and 3, 2000, respondent conducted an audit of
petitioner’s taxable years 1996 and 1997. During the audit
petitioner was told that if he did not sign the Form 4549-CG,
Income Tax Examination Changes (Form 4549-CG), respondent would
follow the proper procedures to assess and collect the tax. The
examiner informed petitioner that this could include respondent’s
filing a lien against or levying petitioner’s property.
Petitioner told the examiner he wanted to think about it
overnight before he signed the Form 4549-CG, and he would give
the examiner his answer in the morning.
On May 3, 2000, petitioner signed a Form 4549-CG accepting
respondent’s adjustments for 1996 and 1997. Petitioner signed
the Form’s “Consent to Assessment and Collection,” which reads as
follows:
Consent to Assessment and Collection - I do not wish to
exercise my appeal rights with the Internal Revenue Service
or to contest in the United States Tax Court the findings in
this report. Therefore, I give my consent to the immediate
assessment and collection of any increase in tax and
penalties, and accept any decrease in tax and penalties
shown above, plus additional interest as provided by law.
* * *
After the audit, the examiner stated in his notes:
Despite the numerous frivolous filer information in the back
of this case file, the taxpayer, Gregory Shireman, wants to
fully cooperate with the IRS in getting his tax returns in
order. Since the initial filing of the 1996-1997 Substitute
for Returns, he has signed the audit report for these years
and now wants to file his 1998-1999 1040's at the time he
submits his Offer and Compromise with Collection.
* * * * * * *
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Last modified: May 25, 2011