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such activity took place; i.e., the issuance of the statutory
notice of deficiency, making of tax assessments, and application
of withholding credits. Petitioner did not respond to the
statutory notice covering taxable year 1987.
On May 27, 1991, the Center issued petitioner a first notice
of balance due for the 1987 taxable year. The first notice of
balance due explained the calculations used, the income producing
the assessment, and the balance due of $31,275.28. Normally, if
a response is not received for the first notice, the Center's
computer system subsequently issues other notices, indicating
that there is a balance due. The Center sent petitioner three
additional notices on July 1, August 5, and September 9, 1991,
all showing a balance due for 1987 of $31,275.28. The Center
received no response or payments from petitioner for the notices
of balance due, and on October 14 and November 18, 1991, issued
notices of intent to levy on the balance due of $31,275.28. On
September 8 and 30, 1992, the Center received payments from
petitioner for his 1987 taxable year in the amounts of $5.23 and
$21.39, respectively.
On November 30, 1990, the Center established an account for
petitioner for his 1988 taxable year by preparing a substitute
for return. A statutory notice for petitioner's 1988 taxable
year was issued, and petitioner did not respond. On September 2,
1991, the Service assessed a $2,239 deficiency in tax for
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