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Petitioner gave Mr. Chivers the 1989 return. It was obvious
to Mr. Chivers that petitioner did not earn the amount of money
reported on the 1989 return and that he was drunk.
On April 7, 1992, respondent assessed income tax, penalties,
and interest with respect to petitioner’s 1986, 1987, and 1988
tax years. Petitioner had the opportunity to petition the Tax
Court for 1986, 1987, and 1988, but he chose not to because he
lacked the money to contest the proposed deficiencies.
On May 11, 1992, based upon the 1989 return filed on October
4, 1991, respondent assessed $1,398,726 in income tax, a
$349,681.50 penalty, and $397,559.58 in interest with respect to
petitioner’s 1989 tax year.
On September 4, 1992, respondent filed notices of Federal
tax liens regarding petitioner’s 1986, 1987, 1988, and 1989 tax
years (1992 liens). Although the IRS tried to collect these
taxes from petitioner, Mr. Chivers concluded that petitioner had
no assets, placed petitioner’s case in uncollectable status, and
closed the case.
On September 20, 1993, based upon a return filed by
petitioner for 1992 listing $1,799.18 in adjusted gross income,
respondent assessed $75.89 in income tax, a $2.27 penalty, and
$2.33 in interest with respect to petitioner’s 1992 tax year.
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