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section 6330.1 At the time the petition was filed, petitioner
resided in Cincinnati, Ohio.
The facts may be summarized as follows. Respondent issued
notices of deficiency determining deficiencies in petitioner’s
Federal income taxes and additions to tax (rounded to the nearest
dollar) as follows:
Additions to Tax
Year Deficiency Sec. 6651(a) Sec. 6654
1993 $3,629 $649 $103
1994 4,845 1,100 222
1995 5,564 1,198 255
1996 6,613 1,361 283
The notices were sent to petitioner at 6727 High Meadows Drive,
Cincinnati, Ohio 45230. This is the same address shown on the
petition filed in this case. Petitioner did not file a petition
to seek review of respondent’s determinations of the deficiencies
and additions to tax, and respondent assessed the liabilities.
On or about July 28, 1999, respondent sent a notice of intent to
levy, and petitioner requested a hearing pursuant to section
6330. On May 1, 2000, after a hearing before an Appeals officer,
respondent notified petitioner that her objections to collection
were denied.
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
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Last modified: May 25, 2011