- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011