-3-
During the years under consideration, petitioner was a program
manager with the Joint Oceanographic Institutions, Inc., in
Washington, D.C.
In 1989, petitioner earned $49,544 in wages, $39 in taxable
interest income, and $722 in dividend income; he paid $8,484 in
withholding tax that year. In 1990, petitioner earned $50,497 in
wages, $29 in taxable interest income, and $266 in dividend income;
he paid $7,790 in withholding tax that year. The withholding tax
payments constitute the sole payments received by respondent with
regard to petitioner’s 1989 and 1990 tax years. Petitioner has no
record that he filed his 1989 or 1990 tax returns. He did not send
the returns by certified or registered mail. Petitioner did not
use a tax return preparer to prepare his 1989 or 1990 tax returns.
The Internal Revenue Service’s (IRS) tax module indicates that
petitioner neither filed 1989 or 1990 tax returns nor claimed a
credit or refund for a 1989 or 1990 overpayment. The IRS sent
letters to petitioner requesting that he file 1989 and 1990
returns. Petitioner claims he never received any such letters.
The letters were not returned to the IRS as undeliverable.
On March 29, 1993, the IRS (under the authority of section
6020(b)), constructed 1989 and 1990 returns for petitioner from
payor information documents. The notices of deficiency, which were
mailed to petitioner’s last known address on July 3, 1993, are
based on these substitute returns, and the deficiency tax
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011