Ronald Lee Snyder - Page 10

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                                  BRIEF BACKGROUND                                    
               The taxpayer filed voluntary income tax returns for                    
               1991, 1994, 1996.  The Collection Statute has since                    
               expired on the 1991 tax liability.  The taxpayer filed                 
               frivolous returns for 1997, 1998 and 1999.  Frivolous                  
               return penalties were assessed for each of these three                 
               years.  The taxpayer has filed no income tax returns                   
               since 1999 even though income information reported to                  
               the Internal Revenue Service indicates that he would                   
               have a filing requirement.                                             
                  *       *       *       *       *       *       *                   
               I.   Verification of Legal and Procedural Requirements                 
               The required notice and demand was sent for each period                
               on the same date as the assessment.                                    
                  *       *       *       *       *       *       *                   
               With the best information available including computer                 
               records and the administrative file it has been deter-                 
               mined that all applicable legal and administrative                     
               requirements have been met.                                            
               This settlement officer has had no known previous                      
               dealings with this taxpayer for the tax liability for                  
               the periods listed above.                                              
               II. Issues Raised by the Taxpayer                                      
               The taxpayer had an earlier opportunity to raise issues                
               concerning the underlying tax liability for the 1998                   
               and 1999 tax liability.  A Statutory Notice of Defi-                   
               ciency (SND) was issued for these assessments.  It is                  
               known that the taxpayer received a copy of this notice                 
               because he provided a copy of it with his appeal re-                   
               quest.  The tax liability on earlier periods [including                
               1994 and 1996] is based upon voluntarily filed tax                     
               returns.                                                               
               The taxpayer was given an opportunity to raise the                     
               issue of the underlying tax liability with regards to                  
               the Frivolous Income Tax Return Civil Penalty under IRC                
               � 6702 for the tax periods listed above.  The taxpayer                 
               did not present any relevant, non-frivolous documenta-                 
               tion to challenge the liability.                                       





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Last modified: May 25, 2011