4
On the same day he filed the Form 2848 for taxable year
1987, petitioner filed a Form 872 (Consent to Extend the Time to
Assess Tax) extending the time for assessment for his 1987 tax
year until April 15, 1993. On the Form 872, petitioner listed
his residence as the Mansfield address. On January 15, 1993,
petitioner filed his 1989 and 1990 Federal income tax returns,
listing his residence as the Mansfield address on the 1989 return
and as 2300 Lohman's Crossing, Suite 190, Austin, Texas 78734
(the Lohman address) on the 1990 return. The Lohman address is
the location of petitioner's business office.
On April 9, 1993, respondent mailed a notice of deficiency
determining the following deficiencies in, and additions to,
petitioner's Federal income taxes for years 1984, 1986, and 1987:
Additions to Tax
Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(a)(1) 6653(a)(2) 6661(a)
1984 $64,118 -- $3,206 1 $16,030
Additions to Tax
Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(a)(1)(A) 6653(a)(1)(B) 6661(a)
1986 $5,973 -- $299 1 $1,493
1987 55,867 $12,061 2,793 1 13,967
1 50 percent of the interest computed on the portion of the underpayment which1
is attributable to negligence or intentional disregard of rules and regulations.
Respondent's adjustments to petitioner's 1984 and 1986 taxable
years are entirely the result of respondent's disallowance of
petitioner's NOL for 1987. The notice of deficiency was mailed
by certified mail to petitioner at the following addresses: (1)
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