HORN v. COMMISSIONER
United States Tax Court
P appeals under sec. 6330(d)(1), I.R.C., from R's determination to proceed by levy to collect unpaid Federal assessments of income taxes, failure to pay additions, and accrued interest for tax years 1990-94 and 1996. 1. Held: P was mentally competent when he signed Forms 4549-CG, Income Tax Examination Changes, for 1990-93; by signing Forms 4549-CG, P waived his rights to dispute the tax liabilities for those years prior to assessment and thereby conclusively acknowledged…
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P appeals under sec. 6330(d)(1), I.R.C., from R's determination to proceed by levy to collect unpaid Federal assessments of income taxes, failure to pay additions, and accrued interest for tax years 1990-94 and 1996. 1. Held: P was mentally competent when he signed Forms 4549-CG, Income Tax Examination Changes, for 1990-93; by signing Forms 4549-CG, P waived his rights to dispute the tax liabilities for those years prior to assessment and thereby conclusively acknowledged that he had an opportunity to dispute those liabilities within the meaning of sec. 6330(c)(2)(B), I.R.C. 2. Held, further,…
1Opinion of the Court
JAMES D. HORN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
HORN v. COMMISSIONER
No. 18502-99L
United States Tax Court
T.C. Memo 2002-207; 2002 Tax Ct. Memo LEXIS 213; 84 T.C.M. (CCH) 204;
August 16, 2002, Filed
Decision was entered for respondent.
P appeals under sec. 6330(d)(1), I.R.C., from R's
determination to proceed by levy to collect unpaid Federal
assessments of income taxes, failure to pay additions, and
accrued interest for tax years 1990-94 and 1996.
1. Held: P was mentally competent when he signed
Forms 4549-CG, Income Tax Examination Changes, for 1990-93; by
signing Forms…
2Cases cited31 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Sego v. CommissionerUnited States Tax Court · 2000
- Vanicek v. CommissionerUnited States Tax Court · 1985
- Petzoldt v. CommissionerUnited States Tax Court · 1989
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