Mitchell F. Skrizowski - Page 2

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                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  At the time he filed the            
          petition, petitioner resided in Manchester, New Hampshire.                  
          Petitioner’s Activities Before 1990                                         
               During and prior to 1989, petitioner was in the business of            
          buying, selling, and renting real estate.  In 1989, the number of           
          vacancies in petitioner’s real estate increased.  Petitioner sold           
          his home and exhausted all of his cash, but was unable to pay the           
          mortgages on the real estate he owned.  The real estate was                 
          foreclosed upon.  Around this time, petitioner and his wife                 
          separated.                                                                  
          Respondent’s Assessments and Attempt To Collect Taxes                       
               Around 1990, petitioner received a letter from the Internal            
          Revenue Service (IRS) that stated he owed $250,000 in taxes for             
          1987.  Around September 1991, Revenue Officer Boyd Chivers was              
          assigned to collect taxes from petitioner and Lafayette Oil Co.2            
          Mr. Chivers’s concerns were that petitioner was not filing                  
          returns and was not declaring money that he earned.  At that                



               2  Petitioner purchased Lafayette Oil Co. for $50,000, and,            
          in 1989, sold it to Robert Hicks.  Mr. Hicks paid petitioner                
          $25,000 and promised to pay petitioner $5,000 per month for 5               
          years.  Mr. Hicks never made any of the $5,000 payments.                    
          Respondent’s collection actions concerning taxes owed by                    
          Lafayette Oil Co. are not in issue in this proceeding.                      




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