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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 of
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Last modified: May 25, 2011