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Background
On October 29, 1998, respondent issued a notice of
deficiency to petitioner determining a deficiency of $2,891 in
his Federal income tax for 1997. The notice of deficiency may
not have been mailed to petitioner at his last known address. In
any event, the notice of deficiency was returned to respondent by
the Postal Service and was not received by petitioner.
On November 18, 1998, respondent issued a notice of
deficiency to petitioner determining deficiencies of $2,126 and
$2,623 in his Federal income taxes for 1995 and 1996,
respectively. This notice of deficiency was mailed to petitioner
at his last known address. Petitioner does not assert that he
did not receive the notice of deficiency.2 However, petitioner
failed to file a petition with the Court challenging the notice
of deficiency pursuant to section 6213(a).
On October 14, 1999, respondent mailed to petitioner a Final
Notice/Notice Of Intent To Levy And Notice Of Your Right To A
Hearing (notice of intent to levy) pursuant to section 6331(a).
The notice stated that petitioner owed taxes and statutory
additions totaling $1,453.37, $3,267.96, and $3,307.40 for the
1(...continued)
Practice and Procedure and, unless otherwise indicated, all
section references are to the Internal Revenue Code, as amended.
2 Indeed, petitioner attached a partial copy of this notice
of deficiency to his petition.
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Last modified: May 25, 2011