Harold L. Perry - Page 3

                                        - 3 -                                         

               On April 11, 1997, respondent issued a notice of deficiency            
          to petitioner determining a deficiency in, and additions to, his            
          Federal income tax for 1991.  In the notice of deficiency                   
          respondent determined that petitioner failed to file a Federal              
          income tax return for 1991 and report thereon certain income (as            
          reported to respondent by various payers) received by him during            
          that year.                                                                  
               In response to the above-mentioned notice of deficiency, on            
          July 14, 1997, petitioner filed a timely petition with the Court.           
          He was residing in Oakland, California, at that time.  In the               
          petition, petitioner:  (1) Admits that he did not file a Federal            
          income tax return for the year 1991; (2) alleges that he has been           
          denied the opportunity to meet with respondent to discuss his tax           
          liability for that year; and (3) alleges that respondent failed             
          to respond to his March 3 letter, in which he "requested                    
          information" from respondent.  The petition does not assign error           
          to any of the adjustments made in the notice of deficiency, nor             
          contain any allegations of fact in support of any assignments of            
          error.  In the prayer for relief, petitioner requests "that this            
          matter be referred back to the Commissioner with instructions               
          that the Commissioner respond to * * * [his] request for                    
          information".  Petitioner's March 3 letter is attached to, and              
          incorporated by reference into, the petition.                               







Page:  Previous  1  2  3  4  5  6  7  Next

Last modified: May 25, 2011