Date: Sun, Nov 29, 2015 at 4:34 PM
Subject: Fwd: Fw: RE: Genesis of a Tax Court dispute
To: alan hootnick <ahootnick@yahoo.com>, "*IRS.Commisioner" <*IRS.Commisioner@irs.gov>, Washington Field <washington.field@ic.fbi.gov>, ASKDOJ <ASKDOJ@usdoj.gov>, "Division, Criminal" <Criminal.Division@usdoj.gov>, "Doug.Davis" <Doug.Davis@ftb.ca.gov>, Dennis <Dennis@riordan-horgan.com>, MollyHale <MollyHale@ucia.gov>, nsapao <nsapao@nsa.gov>, fsb <fsb@fsb.ru>, rbyucaipa <rbyucaipa@yahoo.com>, khuvane <khuvane@caa.com>, blourd <blourd@caa.com>, Robert MacMillan <robert.macmillan@gmail.com>, a <anderson.cooper@cnn.com>, wennermedia <wennermedia@gmail.com>, Mick Brown <mick.brown@telegraph.co.uk>, "glenn.greenwald" <glenn.greenwald@firstlook.org>, Harriet Ryan <harriet.ryan@latimes.com>, "hailey.branson" <hailey.branson@latimes.com>, Stan Garnett <stan.garnett@gmail.com>, Mike Feuer <mike.feuer@lacity.org>, "mayor.garcetti" <mayor.garcetti@lacity.org>, Opla-pd-los-occ <OPLA-PD-LOS-OCC@ice.dhs.gov>, "Kelly.Sopko" <Kelly.Sopko@tigta.treas.gov>, Whistleblower <whistleblower@judiciary-rep.senate.gov>, Attacheottawa <AttacheOttawa@ci.irs.gov>, tips@radaronline.com, Paulmikell.A.Fabian@irscounsel.treas.gov
Alan Hootnick,
I have no idea why my Criminal Stalker sent this email to you or why it was forwarded to me. If you are interested in this situation, please refer to my riverdeepbook.blogspot.com. I have carefully documented the conduct of Gianelli who I view as a potential escapee from a criminal mental asylum and professional criminal.
It does appear as though Gianelli has concerns about security issues and possibly believes you are attempting to "mind control" him. I wouldn't worry too much as he seems like a brainless ambulance chaser in bed with Spector's prosecutors and Leonard Cohen.
For the record, there is fraud and perjury involved with every Cohen related matter that relates to me. For Leonard Cohen, this is merely another opportunity to flaunt yet another fabricated and self-serving narrative. As you might imagine, Phil Spector could not stand this man and thought he was a talentless porn artist with biblical references.
Kelley Lynch
---------- Forwarded message ----------
From: alan hootnick <ahootnick@yahoo.com>
Date: Sun, Nov 29, 2015 at 12:55 PMSubject: Fw: RE: Genesis of a Tax Court dispute
To: Kelley Lynch <kelley.lynch.2010@gmail.com>
--- On Sun, 11/29/15, alan hootnick <ahootnick@yahoo.com> wrote:
From: alan hootnick <ahootnick@yahoo.com>
Date: Sun, Nov 29, 2015 at 12:55 PMSubject: Fw: RE: Genesis of a Tax Court dispute
To: Kelley Lynch <kelley.lynch.2010@gmail.com>
--- On Sun, 11/29/15, alan hootnick <ahootnick@yahoo.com> wrote:
>
> ------------------------------
> On Sun, 11/29/15, Stephen R. Gianelli <stephengianelli@gmail.com>
> wrote:
>
> Subject: RE: Genesis of a Tax Court dispute
> To: "'alan hootnick'" <ahootnick@yahoo.com>
> Date: Sunday, November 29, 2015, 3:10 PM
>
> ------------------------------
> On Sun, 11/29/15, Stephen R. Gianelli <stephengianelli@gmail.com>
> wrote:
>
> Subject: RE: Genesis of a Tax Court dispute
> To: "'alan hootnick'" <ahootnick@yahoo.com>
> Date: Sunday, November 29, 2015, 3:10 PM
>
She feels very entitled. If it
> benefits her, it must be right. She really does not want
> to
> consider an opposite point of view other than what she
> wants. If a court rules against her (which is every time
> she
> gets involved in a legal proceeding – because her view
> of
> “reality” is so self-serving and unreasonable) there
> was
> "perjury" or "fraud" of the judge
> was" corrupt". And, win lose or draw if she feels
> she is making Leonard Cohen's life miserable, it was
> worth it. The larger picture, to me, is how
> silly it is for even a layperson to think that you can ask
> any court - the tax court, the LA court, any court - to go
> unwind a legal judgement or decision or settlement that
> you
> did not participate it that occurred a decade or more ago.
> If she can attack Leonard Cohen's stipulated tax court
> decision reached 2003 in a case Cohen filed in tax court
> in
> 2001 concerning tax matters relating to 1999 - then there
> would be no finality or certainty in the world. Any pissed
> off employee, former spouse or former neighbor or cocktail
> waitress you slighted could cause the IRS to set aside
> other
> business and reopen another citizens tax matter from 15
> years ago. Or a plaintiff who wins title to real estate
> and
> builds a 600 room hotel on the property would have to
> worry
> about someone coming out of the woodwork 10 years later
> claiming title because "they weren’t served".
> That is why the underlying policy
> of the law favors FINALITY over the justice of a give case
> at a certain point. Consequently, defendants have 6-months
> in most cases to file a motion to set aside a default
> judgment in most cases and an outside time limit of
> 2-years
> in an additional, more narrow set of cases, but in all
> cases
> must file the motion as soon as they discover (or should
> have discovered with reasonable diligence) the grounds to
> file the motion - whichever is sooner. That is why
> we don't allow one
> tax payer to contest the tax affairs of another and why
> there are statutes of limitation for civil
> claims. CERTAINTY. Capitalism cannot work
> without it. Banks could not loan money and investors could
> not assess financial risk and title companies could not
> insure transactions. You can usually predict legal
> outcomes by understanding a few basic underlying
> principles.
> But not if you don’t want to understand. BTW, how come
> your emails are
> formatted in text instead of HTML? Is it
> security?
>
> benefits her, it must be right. She really does not want
> to
> consider an opposite point of view other than what she
> wants. If a court rules against her (which is every time
> she
> gets involved in a legal proceeding – because her view
> of
> “reality” is so self-serving and unreasonable) there
> was
> "perjury" or "fraud" of the judge
> was" corrupt". And, win lose or draw if she feels
> she is making Leonard Cohen's life miserable, it was
> worth it. The larger picture, to me, is how
> silly it is for even a layperson to think that you can ask
> any court - the tax court, the LA court, any court - to go
> unwind a legal judgement or decision or settlement that
> you
> did not participate it that occurred a decade or more ago.
> If she can attack Leonard Cohen's stipulated tax court
> decision reached 2003 in a case Cohen filed in tax court
> in
> 2001 concerning tax matters relating to 1999 - then there
> would be no finality or certainty in the world. Any pissed
> off employee, former spouse or former neighbor or cocktail
> waitress you slighted could cause the IRS to set aside
> other
> business and reopen another citizens tax matter from 15
> years ago. Or a plaintiff who wins title to real estate
> and
> builds a 600 room hotel on the property would have to
> worry
> about someone coming out of the woodwork 10 years later
> claiming title because "they weren’t served".
> That is why the underlying policy
> of the law favors FINALITY over the justice of a give case
> at a certain point. Consequently, defendants have 6-months
> in most cases to file a motion to set aside a default
> judgment in most cases and an outside time limit of
> 2-years
> in an additional, more narrow set of cases, but in all
> cases
> must file the motion as soon as they discover (or should
> have discovered with reasonable diligence) the grounds to
> file the motion - whichever is sooner. That is why
> we don't allow one
> tax payer to contest the tax affairs of another and why
> there are statutes of limitation for civil
> claims. CERTAINTY. Capitalism cannot work
> without it. Banks could not loan money and investors could
> not assess financial risk and title companies could not
> insure transactions. You can usually predict legal
> outcomes by understanding a few basic underlying
> principles.
> But not if you don’t want to understand. BTW, how come
> your emails are
> formatted in text instead of HTML? Is it
> security?
>
> 11/29/15, Stephen
> R. Gianelli <stephengianelli@gmail.com>
> wrote: Subject: Genesis of a Tax
> Court dispute To:
> ahootnick@yahoo.com
> Date: Sunday, November
> 29, 2015, 4:11 AM
> Genesis of a Tax Court disputeMany
> Tax Court cases
> involve disputes over Federal income tax and penalties,
> often after an examination by the Internal Revenue
> Service
> of a taxpayer's return. After issuance of a series of
> preliminary written notices and a lack of agreement
> between the taxpayer and the IRS, the IRS formally
> "determines" the amount of the
> "deficiency" and issues a formal notice called a
> "statutory notice of deficiency," or "ninety
> day letter" In this context, the term
> "deficiency" is a legal term of art, and is not
> necessarily equal to the amount of unpaid tax (although
> it
> usually is). The deficiency is generally the excess of
> the
> amount the IRS contends is the correct tax over the
> amount
> the taxpayer showed on the return—in both cases,
> without
> regard to how much has actually been paid. Upon issuance
> of the statutory notice of deficiency (after IRS
> determination of the tax amount, but before the formal
> IRS
> assessment of the tax), the taxpayer generally has 90
> days to file a Tax Court petition for
> "redetermination of the deficiency". If no
> petition is timely filed, the IRS may then statutorily
> "assess" the tax. To "assess" the tax
> in this sense means to administratively and formally
> record the tax on the books of the United States
> Department of the Treasury. This formal statutory
> assessment is a critical act, as the statutory tax lien
> that later arises is effective retroactively to the date
> of the assessment, and encumbers all property and rights
> to property of the taxpayer.
> R. Gianelli <stephengianelli@gmail.com>
> wrote: Subject: Genesis of a Tax
> Court dispute To:
> ahootnick@yahoo.com
> Date: Sunday, November
> 29, 2015, 4:11 AM
> Genesis of a Tax Court disputeMany
> Tax Court cases
> involve disputes over Federal income tax and penalties,
> often after an examination by the Internal Revenue
> Service
> of a taxpayer's return. After issuance of a series of
> preliminary written notices and a lack of agreement
> between the taxpayer and the IRS, the IRS formally
> "determines" the amount of the
> "deficiency" and issues a formal notice called a
> "statutory notice of deficiency," or "ninety
> day letter" In this context, the term
> "deficiency" is a legal term of art, and is not
> necessarily equal to the amount of unpaid tax (although
> it
> usually is). The deficiency is generally the excess of
> the
> amount the IRS contends is the correct tax over the
> amount
> the taxpayer showed on the return—in both cases,
> without
> regard to how much has actually been paid. Upon issuance
> of the statutory notice of deficiency (after IRS
> determination of the tax amount, but before the formal
> IRS
> assessment of the tax), the taxpayer generally has 90
> days to file a Tax Court petition for
> "redetermination of the deficiency". If no
> petition is timely filed, the IRS may then statutorily
> "assess" the tax. To "assess" the tax
> in this sense means to administratively and formally
> record the tax on the books of the United States
> Department of the Treasury. This formal statutory
> assessment is a critical act, as the statutory tax lien
> that later arises is effective retroactively to the date
> of the assessment, and encumbers all property and rights
> to property of the taxpayer.
