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addition to tax for that year under section 6651(a) in the amount
of $304.2
Background
At the time petitioner filed the petition, he indicated
therein that his address was New York, New York.
In her motion, respondent represents various facts, none of
which petitioner has disputed, including the following.3
On June 23, 1995, respondent filed an answer denying the
allegations in the petition, including petitioner's allegation
that assessment of the tax determined in the notice of deficiency
(notice) is barred by the applicable statute of limitations. The
answer also affirmatively alleged that the applicable statute of
limitations did not preclude assessment of the tax determined in
the notice because petitioner failed to file an income tax return
for the year at issue.
On January 30, 1996, respondent sent a letter to petitioner
that invited him to a conference on February 5, 1996, and infor-
mally requested that petitioner bring various documents to that
conference and engage in informal discussions necessary to the
preparation of this case. That letter also advised petitioner
that if the date set for the conference was inconvenient, he
2 Respondent also determined interest on those amounts as
provided by law.
3 Although the Court ordered petitioner to file a response to
respondent's motion, he failed to do so.
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