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5. You are consulted by Kal Koke regarding the following situation. Kal tells you that he is an unregistered pharmacist dealing primarily in certain controlled

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5. You are consulted by Kal Koke regarding the following situation. Kal tells you that he is an unregistered "pharmacist" dealing primarily in certain controlled substances. He explains that he has just received a notice of termination assessment of income tax under Code Sec. 6851. The assessment resulted from a raid on Kal's home on July 1,202. In that raid, the government seized $500,000 in cash. As Kal explains it, the IRS determined that $500,000 constituted his gross receipts for that week. The IRS has now assessed him for income tax for the period January 1 through July 1,202. The IRS has computed his income to be $13,000,000 and is seeking tax of approximately $5,000,000. In addition, the IRS is holding the $500,000 seized for eventual application to the tax liability for the year. Kal said that he objected to this assessment and asked for review. His grounds for review were as follows: (1) $500,000 only constituted his gross receipts for a month, not for a week and (2) the IRS failed to give any effect to his cost of goods sold, which he estimates to be approximately $260,000 per month. The request for review of the assessment has been denied. Kal wants to know what he can do next! He is willing to pay for "successful" advice. 5. You are consulted by Kal Koke regarding the following situation. Kal tells you that he is an unregistered "pharmacist" dealing primarily in certain controlled substances. He explains that he has just received a notice of termination assessment of income tax under Code Sec. 6851. The assessment resulted from a raid on Kal's home on July 1,202. In that raid, the government seized $500,000 in cash. As Kal explains it, the IRS determined that $500,000 constituted his gross receipts for that week. The IRS has now assessed him for income tax for the period January 1 through July 1,202. The IRS has computed his income to be $13,000,000 and is seeking tax of approximately $5,000,000. In addition, the IRS is holding the $500,000 seized for eventual application to the tax liability for the year. Kal said that he objected to this assessment and asked for review. His grounds for review were as follows: (1) $500,000 only constituted his gross receipts for a month, not for a week and (2) the IRS failed to give any effect to his cost of goods sold, which he estimates to be approximately $260,000 per month. The request for review of the assessment has been denied. Kal wants to know what he can do next! He is willing to pay for "successful" advice

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