- 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