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Background
The record establishes and/or the parties do not dispute the
following.
Petitioner resided in Ridgewood, New York, at the time he
filed the petition in this case.
Petitioner did not timely file a Federal income tax (tax)
return for any of his taxable years 1995, 1996, 1997, 1999, and
2000.
On April 17, 2002, respondent issued to petitioner a notice
of deficiency (notice) with respect to his taxable years 1995,
1996, 1997, 1999, and 2000. In that notice, respondent deter-
mined the following deficiencies in, and additions to, the tax of
petitioner:
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6651(a)(1)2 6651(a)(2) 6654
1995 $50,198 $12,550 $0 $2,722
1996 13,567 3,053 3,392 722
1997 36,327 8,174 7,629 1,944
1999 18,363 4,132 1,653 889
2000 14,280 3,213 428 768
Petitioner did not file a petition with the Court with
respect to the notice relating to his taxable years 1995, 1996,
1997, 1999, and 2000.
2All section references are to the Internal Revenue Code in
effect at all relevant times. All Rule references are to the Tax
Court Rules of Practice and Procedure.
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Last modified: May 25, 2011