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criminal investigation of petitioner for possible violation of
the internal revenue laws. During the criminal investigation of
petitioner, the IRS suspected that petitioner’s criminal activity
occurred with respect to taxable years 1983, 1984, and later
years. Petitioner eventually entered into a plea agreement as a
result of the investigation, and the IRS closed its investigation
on February 18, 1990.
Petitioner’s Income Tax and Section 6330 Proceedings
As a result of the decision in Lumenetics, the partnership
losses on petitioner’s returns for 1982, 1983, and 1984, as
described above, were disallowed by the IRS, and deficiencies
were assessed against petitioner and Mrs. Tashjian. On July 19,
1993, the IRS assessed an individual income tax liability against
petitioner in the amount of $29,565 for 1983 relating to
Lumenetics. Additionally, on June 4, 1996, the IRS sent to
petitioner a Form 4549A-CG, Income Tax Examination Changes,
explaining how disallowances made during the TEFRA examinations
of Synergistics for 1982 and Data Flex for 1984 affected his tax
returns for those years. On August 5, 1996, the IRS assessed
income tax liabilities against petitioner in the amounts of
$15,116 and $44,666 for 1982 and 1984, respectively.
A Final Notice, Notice of Intent to Levy and Notice of Your
Right to a Hearing (notice) with respect to petitioner’s unpaid
liabilities was mailed to petitioner on October 28, 2004.
Petitioner timely requested a hearing in response to the notice.
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