Ralph Tashjian - Page 8

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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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