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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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Last modified: May 25, 2011