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shelter and immediate need assistance for food. Also during this
month, petitioner (along with his estranged wife) filed with the
Internal Revenue Service (IRS) a Form 4868, application for an
automatic 4-month extension for filing their income tax return
for 1992.
Nevertheless, petitioner failed to file a Federal income tax
return for 1992. Respondent received information from third
party payers that reflected amounts paid as income to petitioner
during 1992. Based on such information, respondent determined
petitioner's 1992 tax liability.
Prior to issuance of the notice of deficiency, on July 7,
1995, respondent mailed a letter (30-day letter) to petitioner
setting out the proposed deficiency in tax and the additions to
tax recited above. In the computations, respondent allowed
petitioner the standard deduction of $3,000, a personal exemption
of $2,300, and a withholding credit of $351. The 30-day letter
informed petitioner that respondent had no record of his filing a
return for 1992, that respondent had computed the tax liability
based on information provided by payers, that this computation
did not give full credit for exemptions or deductions, and that
petitioner would have to respond within 30 days from the date of
the letter to avoid an assessment based on such computation.
On August 7, 1995, petitioner's attorney mailed respondent a
letter purporting to be a written protest (protest) to the
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