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Petitioner allegedly informed Mr. Champion he did not owe
any material amount of tax to the Internal Revenue Service (IRS)
for the years at issue because he believed that he had sustained
over $8 million of business losses in earlier years that carried
forward to the years in question. Petitioner expected Mr.
Champion to communicate with him regularly, inform him of any
developments in his case, and obtain his consent to any agreement
that would bind him to any tax liability.
On January 14, 2003, Mr. Champion executed on petitioner’s
behalf a Form 4549, Income Tax Examination Changes, consenting to
the immediate assessment and collection of the following
additional taxes, fraud penalties under section 6651(a)(1) and
(f), and interest computed to February 8, 2003, for 1995 and
1996:
Year Tax Penalty Interest
1995 $182,167 $136,625.25 $229,530.82
1996 114,958 86,218.50 115,781.70
On January 14, 2003, Mr. Champion executed on petitioner’s
and Ms. Baird’s behalf a Form 4549 consenting to the immediate
assessment and collection of the following additional tax, fraud
penalty under section 6663(a), and interest computed to February
8, 2003, for 1997:
Year Tax Penalty Interest
1997 $252,079 $84,059.85 $148,078.32
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Last modified: May 25, 2011