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At the time the petition was filed, petitioner resided in
New York, New York. Petitioner's taxable year was the calendar
year. Petitioner did not file returns for 1987 and 1989. On
September 27, 1995, respondent issued a notice of deficiency to
petitioner in which it was determined that petitioner had (i)
taxable income of $22,535 in 1987, of which $7,900 was determined
to be self-employment income, and (ii) taxable income of $31,270
in 1989, of which $12,150 was determined to be self-employment
income. The notice also determined that petitioner was liable
for additions to tax under section 6651(a)(1) for failure to file
for both years.
Petitioner admits that he received taxable income in the
amounts determined, but disputes that any portion of such income
in either year was self-employment income. Petitioner also
disputes his liability for the additions to tax determined by
respondent. Petitioner further contends that, in addition to
relief from the additions to tax, he should be relieved of
liability for some or all interest and should have all issues in
the case resolved in his favor because of errors, omissions, and
delays by respondent that have deprived him of due process.
Denial of Due Process
Petitioner's due process complaint concerns his inability to
obtain redress in these proceedings for what he contends are
various errors, omissions, and delays on the part of respondent,
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