- 3 - Background On October 6, 1995, respondent issued a notice of deficiency to petitioner determining a deficiency of $5,944 in his Federal income tax for 1988, as well as an addition to tax pursuant to section 6651(a)(1) in the amount of $736 and an addition to tax pursuant to section 6654(a) in the amount of $166. Petitioner did not file a petition with the Court contesting the notice of deficiency within the 90-day period prescribed in section 6213(a). The notice of deficiency for 1988 was mailed to petitioner at 7690 Knox Court, Westminster, Colorado 80030, the same address that petitioner used in filing the petition herein. Petitioner does not allege that he did not receive the notice of deficiency, and respondent has no record that the notice was returned by the U.S. Postal Service to respondent as undelivered. On January 24, 2000, respondent mailed a final notice of intent to levy to petitioner. See sec. 6331. The notice stated that petitioner owed tax and additional amounts totaling $8,309.06 for the taxable year 1988 and that respondent was preparing to collect this amount. The notice also stated that petitioner would be given 30 days to request an Appeals Office hearing. Petitioner requested a hearing with respondent's Appeals Office. On July 12, 2000, the Appeals Office issued a Notice ofPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011